Anchor Capital Advisors LLC
Proxy Voting Policies and Procedures Summary Disclosure

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. A 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.

Essentially 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. The Investment Policy Committee (IPC) shall be responsible for general oversight of Proxy Voting Policies and Procedures.

It shall be the responsibility of the CPVO to review all proxies solicited on behalf of our clients, to analyze the questions and propositions being proposed, to make a determination, in consultation with the IPC, how each proposal might effect and impact the financial and economic interests of our clients, and to execute that vote which is deemed to represent the most favorable short and long term economic interests of our clients.

The CPVO shall give especially close attention to proposals affecting the value or future value of our clients’ investments. The CPVO shall be responsible for reviewing all Proxy statements in order to determine which proposals might be controversial, which proposals are deemed in the best interests of our client shareholders and which might not. The IPC, in consultation with the CPVO, shall make a determination regarding the proper action to take (vote “in favor” or vote “against”), and the CPVO shall provide specific guidelines to the PVA on how to vote on each specific question on each specific proxy.

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.

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:

William P. Rice, Chief Compliance Officer
Anchor Capital Advisors LLC
One Post Office Square
Boston, MA 02109