Consistent with fiduciary obligations, an employee benefit plan must maintain a statement of investment policy designed to further the purposes of the plan and its funding policy. According to the Department of Labor, since the fiduciary act of managing plan assets that are shares of corporate stock includes the voting of proxies, a statement of proxy voting policy would be an important part of any comprehensive statement of investment policy. The term "statement of investment policy" means a written statement that provides the fiduciaries who are responsible for plan investments with guidelines or general instructions concerning various types or categories of investment management decisions, which may include proxy voting decisions.

The plan document or trust agreement may expressly provide a statement of investment policy to guide the trustee or may authorize a named fiduciary to issue a statement of investment policy applicable to a trustee. Even if a statement of investment policy is maintained by a named fiduciary, that fiduciary is still required to monitor the appointed investment manager or trustee.