Anchor Capital Advisors LLC
Proxy Voting Policies

Under Rule 206(4)-6 and amendments to Rule 204-2 under the Investment Advisers Act of 1940, Anchor Capital Advisors has adopted and implemented written policies and procedures for voting proxies on behalf of our clients. The following detailed statement of Policies and Procedures has been developed to govern proxy voting which Anchor Capital undertakes on behalf of clients who have delegated us the authority to vote proxies on behalf of their portfolio holdings. Clients wishing to receive a copy of this detailed statement should write or e-mail us.

The Chief Compliance Officer (CCO) shall be responsible for appointing an officer of the Company to serve as "Chief Proxy Voting Officer (CPVO)" and the CPVO may, in turn, designate a "Proxy Voting Associate (PVA)" to assist in implementation of Proxy Voting Procedures. A subset of the Investment Policy Committee (IPC) is appointed to the Proxy Voting Oversight Committee. The CPVO, as required, consults with the Committee to determine the final vote ("in favor", "against" or "abstain").

The CPVO reviews all proxies solicited on behalf of our clients. The review includes an analysis of the questions and propositions proposed, a determination of how each proposal impacts the financial and economic interests of our clients' investments, and a selection of the votes that represent the most favorable short and long term economic interests of our clients investments.

Among other issues, the CPVO analyzes and considers the Dodd-Frank Bill Say on Pay ("SOP") proposal regarding how and how often shareholders vote on executive compensation. The CPVO then instructs the PVA on how to vote each question on each proxy.

To the extent there is a conflict of interest between or among Anchor, its associates and/or named individuals in a proxy Anchor Capital will not alter its proxy voting policies and procedures. Each vote shall be independent of any affiliation.

Clients who wish may submit, in writing to the CCO, any Client Specific Investment Guidelines or Statements of Investment Objectives containing specific proxy voting instructions. The CPVO shall keep records on all such client-specific instructions and guidelines, and the CPVO shall be responsible for conscientious adherence to such client specific guidelines and instructions. Any client who has not delegated us the authority to vote proxies on their behalf will receive a company's proxy directly.

Clients wishing additional information regarding Proxy Voting or additional information pertaining to specific votes cast on their behalf should submit a request, in writing, to the CCO: