All investment advisers registered with the Securities and Exchange Commission are required to make available to clients their proxy voting policies and procedures which describe how the adviser votes client securities in their best interest and how the adviser deals with material conflicts between its interests and those of its clients. Advisers also must keep a record of how they voted client securities and make that voting record available to clients on request. Vantagepoint Investment Advisers LLC (“VIA”) the investment adviser to the Vantagepoint Funds (“Funds”) has obtained and reviewed the proxy voting policies and procedures for the subadvisers for the Funds. The proxy voting responsibility for the Funds are delegated to the respective Fund’s subadviser(s) subject to ERISA fiduciary standard annual reporting to VIA.
Please find below the proxy voting policies for the Vantagepoint Investment Advisers and each Fund’s subadvisers. For the actual record of the votes cast by the individual subadvisers (Form N-PX) please see the SEC filing for the period July 1, 2008 to June 30, 2009.