Proxy voting

Putnam mutual funds, exchange-traded funds, and institutional investment management clients each have guidelines for proxy voting that support the interests of fund shareholders and encourage strong corporate governance practices at companies in which the funds invest.

Proxy voting and the proxy-voting process for Putnam's clients are managed by our internal Proxy Committee and Legal and Compliance Division. These functions are undertaken with the consistent goal of promoting strong corporate governance, acting in the best interests of our shareholders and clients.

Putnam maintains written proxy-voting guidelines that set forth voting positions on issues that Putnam believes are likely to arise. Putnam has a Proxy Committee that is responsible for setting and reviewing the proxy-voting guidelines. The Proxy Committee is composed of senior investment professionals and Putnam's Head of Sustainability Strategy. The Committee reviews the proxy-voting guidelines and proxy-voting procedures at least annually, approves any amendments considered to be advisable, and considers special proxy issues that may arise from time to time.

Contact us and related information

Putnam Investments
100 Federal Street
Boston MA 02110
1-800-225-1581

Monday – Friday: 8:30 a.m. – 5:00 p.m. Eastern Time

Q&A

  • What is corporate governance?
    • Corporate governance is the method by which companies are managed — beginning at the top with the Board of Directors, to which the CEO reports. Good corporate governance policies and practices mean that the Board has made a commitment to managing the company in the best interest of its shareholders. Putnam believes that companies with strong corporate governance policies have the potential to outperform those with weak corporate governance policies — and are therefore more likely to deliver a better return to investors.

  • What is a proxy vote?
    • By purchasing shares of a company, an individual or institution such as a Putnam mutual fund, ETF, or other client account becomes a shareholder of that company. For example, the New York Stock Exchange requires that companies listed on its exchange hold an annual meeting. Shareholders are invited to attend the meeting in person — or by proxy — to vote on issues brought before the meeting by the company or by other shareholders. Since attending the meeting is very likely inconvenient, most shareholders send in their proxies indicating how they would like to vote. Examples of issues that might be included in a proxy ballot are election of the Board of Directors, executive compensation packages, and approval of mergers or acquisitions.

  • Why is proxy voting of interest to shareholders?
    • Since asset managers like Putnam, through their client accounts, purchase large blocks of shares in companies, proxy votes from Putnam and other mutual fund companies carry substantial weight. Putnam's investment professionals seek to invest in companies that have strong corporate governance practices. Putnam is committed to voting proxies for these companies in the best interest of the shareholders in Putnam-sponsored funds.

  • What do the SEC proxy rules require?
    • In summary, the new SEC proxy rules require that investment companies disclose their proxy voting policies and procedures. In addition, investment companies are required to make the results of their proxy votes for the most recent 12-month period ended June 30 available to shareholders by August 31 of each year.

  • Do the Putnam mutual funds, closed-end funds and ETFs have proxy voting guidelines?
    • Yes. Putnam maintains written proxy-voting guidelines that set forth voting positions on issues that Putnam believes are likely to arise. Putnam has a Proxy Committee that is responsible for setting and reviewing the proxy-voting guidelines. The Proxy Committee is composed of senior investment professionals and Putnam's Head of Sustainability Strategy. The Committee reviews the proxy-voting guidelines and proxy-voting procedures at least annually, approves any amendments considered to be advisable, and considers special proxy issues that may arise from time to time. The newly approved guidelines are now available on this website.

  • What issues do the proxy voting guidelines cover?
    • The proxy voting guidelines cover a variety of issues, including the size and composition of Boards of Directors, independence of the Boards, executive compensation policies, changes in a company's capitalization such as share issuance and repurchases, mergers and acquisitions, and situations unique to non-U.S. companies.

  • What is the intent of Putnam's proxy voting guidelines?
    • Putnam's intent is to vote in ways that improve the quality of corporate governance for companies in which the funds invest. The guidelines provide a consistent stance in favor of policies that Putnam, with input from our investment professionals, believe will improve corporate governance, while establishing flexible procedures to allow votes to be cast on a case-by-case basis when necessary.

  • What is the essence of the Putnam Funds' guidelines?
    • The newly approved proxy voting guidelines of Putnam's emphasize the need for strong Boards of Directors that are independent of company management and that are accountable for the performance and governance of their companies. For example, Putnam's guidelines require that Boards have a majority of independent directors, who are selected by independent members of the Board with no material relationship to the company. The goal is to support independent Boards that act in good faith and in the best interests of shareholders. The newly approved proxy voting guidelines of the Putnam Funds emphasize the need for strong Boards of Directors that are independent of company management and that are accountable for the performance and governance of their companies. For example, Putnam's guidelines require that Boards have a majority of independent directors, who are selected by independent members of the Board with no material relationship to the company. The goal is to support independent Boards that act in good faith and in the best interests of shareholders.

  • Who is responsible for proxy voting for the Putnam Funds?
    • The Trustees of the Putnam Funds have ultimate responsibility for voting the proxies of all securities held in the funds. This responsibility is delegated to Putnam, as the investment adviser to the Putnam mutual funds, closed end funds and ETFs. The Trustees of the Putnam Funds review and approve Putnam's proxy voting guidelines on an at least annual basis.

  • Are there situations not covered by the guidelines?
    • Yes, there may be issues listed on a proxy ballot that are not covered by Putnam's guidelines. In those instances, the proxy is voted in consultation with the fund's portfolio managers.

  • Will the Putnam Funds provide the results of their proxy voting to shareholders?
    • The Putnam Funds will disclose their proxy voting record in accordance with the timetable established by SEC rules. The Putnam Funds' Proxy voting record for the most recent 12-month period ended June 30 is available on this website.

Procedures

The proxy voting procedures below explain the role of the funds' Trustees, Putnam, and the proxy voting service, as well as how the process will work when a proxy question needs to be handled on a case-by-case basis, or when there may be a conflict of interest.

  • The role of the funds' Trustees
    • The Trustees of the Putnam Funds have the ultimate responsibility for voting proxies for the Putnam mutual funds, closed-end funds and ETFs. The Trustees have delegated that authority to Putnam, as the investment adviser to the fund's. The Trustees oversee Putnam's proxy voting program through regular reporting by Putnam to the Trustees and an at least annual review of Putnam's proxy voting guidelines.

  • The role of Putnam, as the funds' investment adviser
    • Proxy voting and the proxy-voting process for Putnam's clients are managed by our internal Proxy Committee and Legal and Compliance Division. These functions are undertaken with the consistent goal of promoting strong corporate governance, acting in the best interests of our shareholders and clients. Putnam maintains written proxy-voting guidelines that set forth voting positions on issues that Putnam believes are likely to arise. Putnam has a Proxy Committee that is responsible for setting and reviewing the proxy-voting guidelines. The Proxy Committee is composed of senior investment professionals and Putnam's Head of Sustainability Strategy. The Committee reviews the proxy-voting guidelines and proxy-voting procedures at least annually, approves any amendments considered to be advisable, and considers special proxy issues that may arise from time to time.

  • The role of the proxy voting service
    • The funds have engaged an independent proxy voting service to assist in the voting of proxies. The proxy voting service is responsible for coordinating with the funds' custodians to ensure that all proxy materials received by the custodians relating to the funds' portfolio securities are processed in a timely fashion. To the extent applicable, the proxy voting service votes all proxies in accordance with the proxy voting guidelines established by the Trustees. The proxy voting service will refer proxy questions to the Putnam's proxy voting team for instructions under circumstances where: (1) the application of the proxy voting guidelines is unclear; (2) a particular proxy question is not covered by the guidelines; or (3) the guidelines call for specific instructions on a case-by-case basis. The proxy voting service is also requested to call to Putnam's proxy voting team's attention specific proxy questions that, while governed by a guideline, appear to involve unusual or controversial issues. The funds also utilize research services relating to proxy questions provided by the proxy voting service and by other firms.

  • Voting procedures for referral items
    • As discussed above, the proxy voting service will refer proxy questions to Putnam's proxy voting team under certain circumstances. When the application of the proxy voting guidelines is unclear or a particular proxy question is not covered by the guidelines (and does not involve investment considerations), Putnam's proxy voting team will assist in interpreting the guidelines and, as appropriate, consult with one or more senior staff members of Putnam's Proxy Committee and Compliance Department on how the funds' shares will be voted.

      For proxy questions that require a case-by-case analysis pursuant to the guidelines or that are not covered by the guidelines but involve investment considerations, Putnam's proxy voting team will refer such questions, through a written request, to Putnam Management's investment professionals for a voting recommendation. Such referrals will be made in cooperation with the person or persons designated by Putnam Management's Legal and Compliance Department to assist in processing such referral items. In connection with each such referral item, the Legal and Compliance Department will conduct a conflicts of interest review, as described below under "Conflicts of Interest," and provide a conflicts of interest report (the "Conflicts Report") to Putnam's proxy voting team describing the results of such review. After receiving a referral item from Putnam's proxy voting team, Putnam Management's investment professionals will provide a written recommendation to Putnam's proxy voting team and the person or persons designated by the Legal and Compliance Department to assist in processing referral items. Such recommendation will set forth (1) how the proxies should be voted; (2) the basis and rationale for such recommendation; and (3) any contacts the investment professionals have had with respect to the referral item with non-investment personnel of Putnam Management or with outside parties (except for routine communications from proxy solicitors). Putnam's proxy voting team will maintain a record of all proxy questions that have been referred to Putnam Management's investment professionals, the voting recommendation, and the Conflicts Report.

  • Conflicts of interest
    • Occasions may arise where a person or organization involved in the proxy voting process may have a conflict of interest. A conflict of interest may exist, for example, if Putnam Management has a business relationship with (or is actively soliciting business from) either the company soliciting the proxy or a third party that has a material interest in the outcome of a proxy vote or that is actively lobbying for a particular outcome of a proxy vote. Any individual with knowledge of a personal conflict of interest (e.g., familial relationship with company management) relating to a particular referral item shall disclose that conflict to the Legal and Compliance Department and otherwise remove himself or herself from the proxy voting process. The Legal and Compliance Department will review each item referred to Putnam Management's investment professionals to determine if a conflict of interest exists and will generate a Conflicts Report for each referral item that (1) describes any conflict of interest; (2) discusses the procedures used to address such conflict of interest; and (3) discloses any contacts from parties outside Putnam Management (other than routine communications from proxy solicitors) with respect to the referral item not otherwise reported in an investment professional's recommendation. The Conflicts Report will also include written confirmation that any recommendation from an investment professional provided under circumstances where a conflict of interest exists was made solely on the investment merits and without regard to any other consideration.