1.   Managers of qualifying venture capital funds shall develop in writing adequate and effective strategies for determining when and how to exercise voting rights held in the qualifying venture capital fund portfolio for the benefit of both the qualifying venture capital fund concerned and its investors.

2.   The strategies referred to in paragraph 1 shall determine the measures to be adopted and procedures to be followed and shall include at least the following steps:

(a)	monitoring of relevant corporate actions;

(b)	ensuring that the exercise of voting rights is in accordance with the investment objectives and policy of the qualifying venture capital fund;

(c)	prevention and management of any conflicts of interest arising from the exercise of those voting rights.

3.   Managers of qualifying venture capital funds shall upon request, provide investors with a summary description of the strategies referred to in paragraphs 1 and 2 and the details of the actions taken pursuant to those strategies.