Principle 6 - Our policy on voting and voting disclosure

Standard Life investments votes all shares for which we have voting authority except when otherwise instructed by the beneficial owner of these shares or, where, for practical reasons (such as share-blocking), this is not appropriate. We use our Global Voting Platform to achieve this. Our Global Voting Platform makes use of the services of Glass Lewis and Institutional Shareholder Services (ISS) who are reputable providers of proxy voting research and voting recommendations. Although both of these providers have their own voting guidelines, we provide our own house guidelines which they are required to follow when making voting recommendations for the portfolios which we manage. We also undertake an assessment of voting opportunities using a three tiered significance approach driven by the market of listing and the size of our holding. For the most significant holdings we will separately undertake a full detailed assessment of any voting opportunity, for a mid-range of significance we will review the voting research and recommendations by ISS or Glass Lewis before instructing our vote and for minor holdings we will rely entirely on the voting decisions made by our advisers. In addition to the tiered approach, we will also review any vote against management proposed by our advisers.

We implement considered policies based on the Governance and Stewardship guidelines approved by our board when voting the shares we manage. We seek to vote our clients' shares in a manner consistent with their best interests. We generally support a board's voting recommendation but we do vote our clients' shares against resolutions which are not consistent with their best interests as shareholders and/or conflict with the spirit of Association of British Insurers (ABI) or other institutional guidance. When making voting decisions, we will also make use of the ABI’s Institutional Voting Information Service (IVIS).

In the event that we vote our clients' shares against a resolution at a UK shareholder meeting, we will always use best endeavours to discuss this with the company beforehand and explain the reasons. We use reasonable endeavours to do so in respect of abstentions.

We do not currently offer a stock lending service to our customers. Certain of our customers do separately arrange the lending of stock held in their name. Should a customer have a stock out on loan, it is their responsibility to make arrangements for it to be recalled should they wish voting to occur.

We disclose our voting records for UK and European shareholder meetings on our website.