Proxy Voting

Aviance Capital Management, LLC

Proxy Voting Policy
Rule 206(4)-6                                                       

In accordance with the requirements of Rule 206(4)-6 under the Investment Advisers Act of 1940 (the “Advisers Act”), Aviance Capital Management, LLC (“ACM”) has adopted the following proxy voting policy with respect to those assets for which a client has vested ACM with discretionary investment management authority (the “assets”).

ACM’s Policy

Unless the client directs otherwise in writing, ACM, in conjunction with its engagement of Egan-Jones Proxy Services ("Egan-Jones"), is responsible for voting client proxies.  Egan-Jones shall vote proxies and other shareholder matters in accordance with the Egan-Jones Proxy Voting Guidelines.   ACM, in conjunction with the services provided by Egan-Jones, shall monitor corporate actions of individual issuers and investment companies consistent with ACM’s fiduciary duty to vote proxies in the best interests of its clients.  With respect to individual issuers, ACM may be solicited to vote on matters including corporate governance, adoption or amendments to compensation plans (including stock options), and matters involving social issues and corporate responsibility. With respect to investment companies (e.g., mutual funds), ACM may be solicited to vote on matters including the approval of advisory contracts, distribution plans, and mergers.  ACM, in conjunction with Egan-Jones, shall maintain records pertaining to proxy voting as required pursuant to Rule 204-2 (c)(2) under the Advisers Act.  Copies of Rules 206(4)-6 and 204-2(c)(2) are available upon written request. Egan-Jones on behalf of ACM shall maintain records pertaining to proxy voting as required pursuant to Rule 204-2 (c)(2) under the Advisers Act.  Copies of Rules 206(4)-6 and 204-2(c)(2) are available upon written request. In addition, information pertaining to how ACM, in conjunction with Egan-Jones, voted on any specific proxy issue is also available upon written request.

Any questions regarding ACM’s proxy voting policy shall be directed to Teresa Koncick, Chief Compliance Officer of ACM.