As a matter of Firm policy and practice, RS Crum Inc. does not vote proxies on behalf of advisory clients. Clients retain the responsibility for receiving and voting proxies for any and all securities maintained in client portfolios. Clients will receive their proxies or other solicitations directly from their custodian or a transfer agent.

RS Crum Inc. might provide advice, if requested, regarding the clients’ voting of proxies. RS Crum Inc. will not be deemed to have proxy voting authority solely as a result of providing advice or information about a particular proxy vote to a client.

For accounts subject to the provisions of the Employee Retirement Income Security Act of 1974 (“ERISA”), the plan fiduciary specifically keeps the authority and responsibility for the voting of any proxies for securities held in the plan accounts.