(Adopted May 20, 2003)                                                           
 

Pursuant to rules established by the Securities and Exchange Commission (the “Commission”), under the Investment Company Act of 1940, as amended, the Board of Trustees of James Advantage Funds (the “Trust”) has adopted the following formal, written guidelines for proxy voting by the Trust.  The Board of Trustees of the Trust oversees voting policies and decisions for each series of the Trust (the “Funds”).
 
Each Fund exercises its proxy voting rights with regard to the companies in the Fund’s investment portfolio, with the goals of maximizing the value of the Fund's investments, promoting accountability of a company’s management and board of directors to its shareholders, aligning the interests of management with those of shareholders, and increasing transparency of a company’s business and operations.

James Investment Research, Inc. has retained Egan Jones (EJ) to serve as the Proxy Service Provider (PSP) for all securities held in portfolios it manages, including the James Advantage Funds and for which it has fiduciary obligation to vote.  As the PSP, EJ shall be responsible for executing all proxy votes according to James' Proxy Voting Policy. To that extent, all meeting notices, requests for voting instructions, share positions and other proxy related materials are sent by the custodians directly to EJ.

In some instances, the adviser may be required cast a proxy vote that may presents a conflict between the interests of a Fund’s shareholders, and those of the adviser or an affiliated person of the adviser.  In such a case, the adviser is instructed to abstain from making a voting decision and to forward all necessary proxy voting materials to the Trust to enable the Board of Trustees to make a voting decision.  When the Board of Trustees of the Trust is required to make a proxy voting decision, only the Trustees without a conflict of interest with regard to the security in question or the matter to voted upon shall be permitted to participate in the decision of how the Fund’s vote will be cast.

A copy of these Proxy Voting Policies and Procedures are available, without charge, upon request, by calling the Trust’s toll-free telephone number at (888)426-7640, and on the Commission’s website at http://www.sec.gov.  The Trust will send a copy of the Trust’s Proxy Voting Policies and Procedures within three business days of receipt of a request, by first-class mail or other means designed to ensure equally prompt delivery.