Proxy Voting Policies

AlphaSimplex Group, LLC Proxy Policy

Under SEC Rule 206(4)-6, investment advisers have fiduciary obligations to their clients if the advisers have authority to vote their clients’ proxies. AlphaSimplex Group, LLC (“AlphaSimplex”) may have the discretion at times to vote proxies for clients. AlphaSimplex understands that proxy voting is an important right of shareholders and reasonable care and diligence must be undertaken to ensure that such rights are properly and timely exercised.

AlphaSimplex has entered into an agreement with an independent third-party proxy voting service provider (“Service Provider”), to provide AlphaSimplex with its research on proxies and to facilitate the electronic voting of proxies. AlphaSimplex has instructed Service Provider to execute all proxies in accordance with its recommendations unless instructed otherwise by AlphaSimplex. In the event that (a) Service Provider is unable to complete/provide its research regarding a security on a timely basis, (b) AlphaSimplex or Service Provider determines that Service Provider has a conflict of interest with respect to voting a proxy, or (c) AlphaSimplex has made a determination that it is in the best interests of the client(s) for AlphaSimplex to vote a proxy, AlphaSimplex will vote in a manner that is consistent with what it believes to be the best interests of the client(s) and in accordance with Proxy Voting Policy and Procedures that it has adopted (the “Procedures”).

Clients may obtain a copy of the Procedures by contacting AlphaSimplex by email at [email protected] or by telephone at 617-475-7100.