Proxy voting and the proxy voting process for Putnam's clients are managed by our internal Proxy Committee and Sustainability Strategy team. 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.
Putnam Investments
100 Federal Street
Boston MA 02110
1-800-225-1581
Monday – Friday: 8:30 a.m. – 5:00 p.m. Eastern Time
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 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.
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 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.
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.
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.