Steven Hartstein
About Steven Hartstein
Steven Hartstein (year of birth: 1963) serves as Chief Compliance Officer (CCO) of IHD (Voya Emerging Markets High Dividend Equity Fund) and the other Voya funds, a role he has held since December 2022. His principal business address is 200 Park Avenue, New York, NY 10169. He is also a Senior Vice President at Voya Investment Management (since December 2022) and previously served as Head of Funds Compliance at Brighthouse Financial and CCO of Brighthouse Funds and Brighthouse Investment Advisers (March 2017–December 2022) . The fund’s independent auditor reported no material weaknesses in internal control over financial reporting as of February 28, 2025, indicating a stable control environment under which the CCO function operates .
Past Roles
| Organization | Role | Years | Strategic impact |
|---|---|---|---|
| Voya Investment Management | Senior Vice President | Dec 2022 – Present | Senior compliance leadership for Voya funds complex |
| Brighthouse Financial, Inc. | Head of Funds Compliance | Mar 2017 – Dec 2022 | Led fund compliance; CCO for Brighthouse Funds and Brighthouse Investment Advisers |
External Roles
- No public-company board roles or external directorships are disclosed for Hartstein in the IHD proxy (officer biography lists only Voya and prior Brighthouse roles) .
Fixed Compensation
Officers of the Funds, including the CCO, are employees of Voya Investments, LLC or its affiliates and are not paid by the Funds. As a result, base salary, target bonus, and actual bonus amounts are not disclosed in Fund filings.
| Component | Amount/Terms |
|---|---|
| Base salary | Not disclosed in Fund proxy; officers are compensated by Voya Investments, LLC or its affiliates, not by the Fund |
| Target bonus % | Not disclosed in Fund proxy |
| Actual bonus paid | Not disclosed in Fund proxy |
| Other cash compensation | Not disclosed in Fund proxy |
Performance Compensation
Details on stock/option awards, performance metrics, and vesting for officers are not included in Fund filings because officers are compensated by Voya Investments, LLC or its affiliates (not by the Fund).
| Incentive type | Metric(s) | Weighting | Target | Actual/Payout | Vesting |
|---|---|---|---|---|---|
| RSUs/PSUs (if any) | Not disclosed | — | — | — | — |
| Stock options (if any) | Not disclosed | — | — | — | — |
| Annual incentive plan | Not disclosed | — | — | — | — |
Officer compensation (including mix of cash vs equity, performance metrics, vesting) is not reported at the Fund level; the proxy states officers are employees of Voya Investments, LLC or its affiliates and “are not paid by any Fund” .
Equity Ownership & Alignment
- Officer share ownership, vested/unvested breakdowns, option holdings, and pledging for Hartstein are not disclosed in the Fund proxy .
- The Board’s stock ownership policy applies to Independent Trustees (minimum holdings equal to the annual retainer) and does not extend to officers .
| Item | Status |
|---|---|
| Beneficial ownership of IHD shares | Not disclosed for officers |
| Ownership as % of shares outstanding | Not disclosed |
| Vested vs. unvested shares | Not disclosed |
| Options (exercisable/unexercisable) | Not disclosed |
| Shares pledged as collateral | Not disclosed |
| Applicable ownership guidelines | Trustee-only policy; not applicable to officers |
Employment Terms
| Term | Disclosure |
|---|---|
| Current role | Chief Compliance Officer, IHD (and other Voya funds) |
| Service start date | 12/2022 – Present |
| Election/tenure mechanics | Officers are elected by the Board and hold office until the next annual meeting and until successors are elected/qualified |
| Contract term/expiration | Not disclosed |
| Severance / Change-of-control | Not disclosed |
| Non-compete / Non-solicit | Not disclosed |
| Clawbacks / tax gross-ups | Not disclosed |
| Compensation payer | Voya Investments, LLC or affiliates (officers not paid by the Fund) |
Performance & Track Record
- Control environment: The independent public accountant reported no material weaknesses in the Fund’s internal control over financial reporting as of February 28, 2025, a positive signal for compliance oversight during Hartstein’s tenure as CCO (12/2022–present) .
- Investment oversight context: The Board operates Investment Review Committees (IRCs) for fund oversight; IRC F monitors IHD (note: IRC disclosure pertains to investment oversight; it does not define CCO compensation or metrics) .
Governance Context (Officer Compensation and Oversight)
- Officer compensation is borne by Voya Investments/affiliates and not by the Fund; the proxy provides Trustee compensation only. Officers’ biographies (including Hartstein’s) are provided in Appendix E; compensation details are not part of Fund-level disclosure .
Investment Implications
- Alignment: Because officer pay is set and paid by Voya Investments (not at the Fund level), there is limited transparency into Hartstein’s cash/equity mix, performance conditions, or vesting. This limits direct assessment of pay-for-performance alignment with IHD shareholders based on Fund filings .
- Retention risk: Officers are elected annually and serve until successors are chosen; no fixed-term employment agreements or severance/CIC terms are disclosed for Hartstein at the Fund level. Retention and incentives therefore hinge on Voya corporate programs rather than Fund-specific arrangements .
- Compliance signal: The auditor’s report noting no material weaknesses in internal controls as of Feb 28, 2025 reduces compliance overhang risk for IHD during Hartstein’s tenure as CCO and supports operational stability from a controls perspective .
- Data gaps for trading signals: No officer-level ownership, pledging, or insider trading disclosures are provided in the Fund proxy for Hartstein, limiting the ability to infer selling pressure or option-related overhang from Fund documents .