PROXY VOTING

Client satisfaction

We believe all our efforts should focus on the satisfaction of our clients. We would like to offer you the best service possible.
In case you have any concerns about our products or our service, we kindly ask you to contact your local distributor, representative or agent for assistance.

Publications relating the Management Comapny and the distribution of our funds:

Pioneer Investments has, in the form of a detailed proxy voting policy, established appropriate and efficient strategies enabling the exercise of voting rights attached to the instruments held in the portfolios to the exclusive benefit of the relevant UCITS.

Pioneer Investments exercises voting rights and where it has authorised investment managers to vote portfolio securities it requires that they do so in accordance with PAMSA’s Proxy Voting Policy, and may engage the services of an independent third party to assist in analyzing proxies, shareholder meeting recommendations, record keeping and voting services provided that the Service Provider shall be required to provide its services in accordance and consistent with the Proxy Voting Policy. Pioneer Investments has the duty to monitor corporate events and to vote the proxies. Pioneer Investments casts the proxy votes in a manner consistent with the best interest of the Funds and shall place those interests ahead of its own. Special consideration is given to issues relating to ethical Funds. PAMSA or its appointees vote all proxies presented in a timely manner.

The PAMSA Proxy Voting Policy summarises Pioneer Investments position on a number of issues solicited by companies held by the Funds and detail monitoring of voting, exception votes, and review of conflicts of interest and ensure that case-by-case votes are handled within the context of the Policy. The Policy contains guiding principles provide a general indication of how Pioneer Investments would vote but do not include all potential voting scenarios. Any interpretation is to be made in accordance with the spirit of the Policy or otherwise to be determined upon referral to the Proxy Voting Committee.

Anti Money Laundering

Please find attached the latest Circular issued by the Commission de Surveillance du Secteur Financier (the "CSSF") on the latest statement issued by the Financial Action Task Force ("FATF") concerning the anti-money laundering and combating the financing of terrorism (AML/FT) regimes of certain jurisdictions.

The PAMSA Complaint Handling Procedure summarises the Management Company’s relevant procedures in accordance with CSSF Regulation N 13-02 relating to the out-of-court resolution of complaint and is intended to ensure that complaints are dealt with properly and promptly.