Privacy Voting Policy
LEUTHOLD WEEDEN CAPITAL MANAGEMENT
PROXY VOTING POLICY
A. General Policy
Leuthold Weeden Capital Management (“LWCM”) will vote proxies for its clients, including each of the Leuthold Funds when authorized to do so by such clients. When LWCM votes proxies it generally follows the so called “Wall Street Rule” (i.e., it votes as management recommends or sells the stock prior to the meeting). LWCM believes that following the “Wall Street Rule” is consistent with the economic best interests of its clients. When management makes no recommendation, LWCM will not vote proxies unless LWCM determines the failure to vote would have a material adverse effect on its clients. If LWCM determines that the failure to vote would have a material adverse effect on its clients, it will vote in accordance with what it believes are the economic best interests of the client. Consistent with its duty of care LWCM monitors proxy proposals just as it monitors other corporate events affecting the companies in which its clients invest. LWCM will “echo” vote (i.e., vote for and against the proposal in the same proportion as all other shareholders) shares of investment companies that it owns inside the Funds to comply with the requirements of Section 12(d)(1) of the 1940 Act.
B. Conflicts of Interest
There may be instances where the interests of LWCM may conflict or appear to conflict with the interests of its clients. For example, LWCM may manage a pension plan of a company whose management is soliciting proxies and there may be a concern that LWCM would vote in favor of management because of its relationship with the company. In such situations LWCM will, consistent with its duty of care and duty of loyalty, “echo” vote the securities (i.e., vote for and against the proposal in the same proportion as all other shareholders).
C. Record Keeping
LWCM will maintain the following records with respect to proxy voting:
• a copy of this proxy voting policy;
• a copy of all proxy statements received (LWCM may rely on the EDGAR system to satisfy this requirement);
• a record of each vote cast on behalf of a client (LWCM may rely on a third party to satisfy this requirement);
• a copy of any document prepared by LWCM that was material to making a voting decision or that memorializes the basis for that decision;
• a copy of each written client request for information on how LWCM voted proxies on the client’s behalf, and a copy of any written response to any (written or oral) client request for information on how LWCM voted proxies on behalf of the requesting client.
LWCM will furnish a copy of this policy to all of its clients. LWCM will disclose to clients and the Board of Directors of the Leuthold Funds, Inc. how proxies were voted upon request. Requests may be made by calling LWCM at 612-332-9141.