Responsibility Matters October 2018 by Royal London Asset Management

RESPONSIBILITY MATTERS

RLAMâ&#x20AC;&#x2122;S RESPONSIBLE INVESTMENT REVIEW OCTOBER 2018

Five things to consider when incorporating ESG across specific asset classes

WE’RE ALL RESPONSIBLE Piers Hillier, Chief Investment Officer, Royal London Asset Management

The Big Interview

It’s hard to get away from the subject of responsible investing (RI) right now. We’re seeing increased interest across all areas of the investing world, with clients asking more questions of us while we ask more of the companies we invest in.

A fiery summer in Britain’s boardrooms

Lifting the lid on emerging markets

Your voice – RLAM voting on your behalf

FOR PROFESSIONAL CLIENTS ONLY, NOT SUITABLE FOR RETAIL INVESTORS.

This obviously reflects the changing emphasis on issues such as diversity in wider society, but we think there is a financial imperative to this too: we believe that investing in ‘good’ companies produces better returns for clients, and that ‘bad’ companies are more likely to disappoint. We’ve always placed an emphasis on good governance at RLAM, an emphasis that received a boost when we took over the Co-op Asset Management in 2013, bringing on board their highly respected sustainable investing team, headed by Mike Fox. We’ve since continued to invest in this area, creating a team with a clear role in helping our fund managers access excellent research on a range of RI factors, both at macro levels such as asset class or sector, and the micro level by looking at individual companies. Whether this is referred to as ESG or responsible investing, this is about far more than putting a team in, but getting investment teams the best inputs to make the best decisions, so that ESG is no more a unique consideration than balance sheet strength.

NEW FORMAT

Our annual Investment Conference in April had a number of RI-related sessions (you can access these here) and interest since then has increased significantly. We’re committed not only to building this capability, but also being transparent in what we do. At a basic level, we do this by publishing our voting data on our website, but this subject is far broader than voting and we want to be sure that you know what we’re doing. As part of this, we’re re-launching this Responsibility Matters e-zine. Here we will provide regular updates on the staples of our responsible investing activities, such as voting trends, but also take a closer look at parts of RLAM to see how these are evolving. We’ll produce Responsibility Matters twice a year, and complement this with webinars and regular blog posts. I hope you enjoy the new magazine. If you have any comments – either on subjects you’d like to see covered or the underlying actions we’ve been taking at RLAM, we’d love to hear from you. Email us at communications@rlam.co.uk

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Five things to consider when incorporating ESG across specific asset classes Thinking about material environmental, social and governance (ESG) issues, and a wider focus on investing responsibly, is becoming an important part of decisionmaking processes for a range of investors, from institutional clients to wealth managers and IFAs. However, integrating this thinking can often require much more nuance than meets the eye. With that in mind, we’ve pulled together a few key questions that you could ask yourself and your asset managers when thinking about how ESG issues might impact your portfolios.

WHAT DATA IS AVAILABLE? For large, publicly listed companies, ESG data is usually both easily accessible and fairly complete, covering a range of key issues. Third-party analytics and scoring are also prevalent. In particular, provisions under the Companies Act for quoted UK companies to disclose their carbon emissions allows direct comparisons within and across industries, over a number of years. However, both disclosures and analysis become patchier, and in some cases the data might not exist, particularly for bonds issued by private companies.

WHAT ANALYSIS IS RELEVANT? Views on ESG factors might vary depending on the type of investment. A bond investor might be encouraged by directors being incentivised to lower a company’s net debt levels, but equity investors might be concerned by management using surplus cash to deleverage the business instead of looking to increase dividends. Even within asset classes, some ESG risks are likely to be more material to certain investors. A fixed income investor holding short-dated, unsecured bonds in an oil company with coastal refineries is unlikely to worry about how the risks of either rising sea levels or efforts to tackle global warming will impact on their returns. But for an investor with bonds secured against these assets over a much longer time period, these risks threaten both future cashflows and the security which backs these up.

Investors need to ask themselves at what level they apply their ESG analysis On the flip side, an unsecured bond investor is likely to be more concerned about the quality of management and their future plans for the business than an investor protected by strong guarantees and covenants. Areas such as board independence might be less important to bondholders if they are already protected by specific covenants and guarantees.

HOW FAR SHOULD YOU ‘LOOK THROUGH’? Investors need to ask themselves at what level they apply their ESG analysis. While an investment trust is itself a listed company with its own board and governance structure, the underlying assets supporting the company’s valuation can be a diverse mix of businesses, each with their own material ESG factors to consider. There are no hard and fast rules over portfolio disclosure and investors might inadvertently end up exposed to risks which they are unaware of. In addition, should shareholders in financial institutions such as commercial banks, which earn money on the interest on the loans they make to other institutions, consider the practices of the underlying sectors which the banks are lending to? However, sometimes investors focusing on the detail of small stakes and subsidiaries can end up missing a bigger picture. An investor wary of exposure to conventional weapons systems might be surprised to learn that blue-chip automotive conglomerates, such as Volkswagen, wouldn’t pass their test. Via an ultimate controlling interest in the subsidiary of a subsidiary of Man SE, the company has exposure to transmission and gearbox systems used in a number of main battle tanks.

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LOOKING FORWARDS, OR LOOKING BACKWARDS? When businesses have suffered scandals, the legacy issues arising from these tend to dog them for a number of years. For an assessment of whether the material risks have passed, investors should consider whether the warning signs for these scandals (far more visible with hindsight) are reflective of forces inside or outside of management’s control. If it’s the former, and the approach and make-up of management haven’t significantly changed, there could be a risk of further scandals.

Like many areas, ESG considerations can be varied and complex For an investment’s day-to-day business, the same principles apply. Should you judge a bank’s exposure to carbon emissions based on the historical makeup of its commercial loan book, or its current policies on reducing exposure? Can an oil company’s historic exposure to deep sea drilling be offset by new capital expenditure in offshore wind production if the old assets are still in operation?

ALTERNATIVE PROBLEMS

Typically, the closer an investor is to an underlying asset, the more control they are able to exert. In purchasing a synthetic alternative to a traditional asset, investors can be exposed without the access to mitigation strategies. For example, investors in a fixed income product designed to mimic the cashflows of certain securities remain exposed to the risks without the legal claim on assets or cashflows available by purchasing underlying bonds. Investors in synthetic equity products can miss out on voting rights or the ability to engage with management. In addition, investors in a direct property fund can push for asset managers to provide them with more information on the material risks impacting the underlying properties. But investors who access their property exposure via a selection of real estate investment trusts remain a little further removed, although they do have a chance to vote on and engage with management. Like many areas, ESG considerations can be varied and complex. But we believe that the five factors described here are a useful starting point for any investor wanting to look at ESG factors and their importance in making investment decisions.

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THE BIG INTERVIEW ‘ If it doesn’t consider ESG factors, it isn’t credit analysis’ Martin Foden, RLAM’s Head of Credit Research, explains what ESG means to him Martin Foden is one of the key cogs in RLAM’s successful credit team. Over the past 20 years, he has worked with Head of Fixed Income, Jonathan Platt, and Head of Credit, Eric Holt, to build a process that now helps look after more than £30 billion of assets. Having researched the debt and equity of many companies across numerous sectors over this time, he is critically aware of the importance of ESG matters for RLAM’s investment teams and clients alike.

It is making sure that your credit analysis is targeted, thorough and able to add value to portfolios “It’s not about ESG and credit analysis – two distinct processes that you have to combine – it is making sure that your credit analysis is targeted, thorough and able to add value to portfolios”, he explains. “We could put in place a shiny new ESG process that would look good but actually add very little value to portfolios. But that is a box-ticking PR approach and we don’t think clients should accept that”.

Instead, Foden and his team are more focused. They have always considered bond investing within the context of lending clients’ money, fixating on anything that decreases the chance of receiving either coupons or principal repayment, weighed against the potential reward for taking that risk.

The reality is that risk doesn’t discriminate “The reality is that risk doesn’t discriminate. Whatever the source of the risk, whether it is poor management decision-making or a missed social liability, the only thing that really matters is its impact. So you have to consider anything that can undermine the sustainability of your borrowers’ balance sheets, irrespective of its origin. If your ‘traditional’ balance sheet analysis is impeccable and you miss an environmental factor that puts the company in trouble, there’s no ESG ‘get out of jail free’ card that dampens the loss.”

NO SHORT CUTS Another important element of a truly effective fixed income ESG process is that it reflects the differences between asset types. “You cannot simply take the same approach as you would for

equities: it’s a tempting short cut but an unhelpful convenience. A great example is the water sector. It’s a relatively small part of any equity universe, as issuers tend to be private companies, so probably doesn’t get a huge amount of attention from third party and equity focused ESG providers. But water utility bonds are a material part

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THE BIG INTERVIEW of the credit universe and an important asset for long-term investors such as pension funds. These companies have a real environmental and social footprint and the financial consequences of this need to be understood 1.” In addition, it is vital that investors understand the different ways that risk can impact different asset classes. “There is a specificity to corporate bond investing that must not be forgotten; it’s not just about who we lend to but how and where – for instance, is our debt secured and covenanted, or are we lending into distinct company subsidiaries? The answer to these questions can have a fundamental impact on how risk is transmitted through the balance sheet.”

There is a specificity to corporate bond investing that must not be forgotten EVOLUTION OF THE APPROACH Foden believes that whilst ESG evaluation has always been an integral element of high quality credit analysis, truly useful ESG integration has to evolve to remain contemporary. Changing environmental risks are a prime example. “Environmental developments can lead to new legislation, as we saw recently with the implementation of new energy standards for UK commercial landlords. This is an area where collaboration between our credit and ESG teams and the benefit of issuer engagement has really paid off. While most debt issuers are happy to engage, are well apprised of the legislation and taking proactive steps to mitigate and protect bond collateral values and cashflows, this is not universal. This

It’s too convenient to assume that management will deliver for shareholders and that bondholders will simply enjoy the ride enhanced insight has improved our understanding of sector and bond risks and, in turn, has helped us assess the additional spread or structural protections we require to compensate for these risks”2. Governance analysis remains critical but needs to be relevant. “We’ve always considered how management actions may impact bondholders, albeit recognising that bond investors’ scope to influence is less than for equity investors who are the ultimate owners of the business. Understanding this control limitation really is the first step to mitigating the risk of management pandering to other stakeholders to the detriment of bondholders. It’s too convenient to assume that management will deliver for shareholders and that bondholders will simply enjoy the ride – corporate history is littered with examples where this has not been the case. Our approach to analysis and building credit portfolios has always focused on addressing this potential misalignment, as well as bondholders’ traditionally weak control once the money has been lent.” Foden believes that mitigation is the key. “Diversification is an obvious element as this reduces the specific risk of individual bond failures. In addition, buying bonds with ring-fenced assets or cashflows, or strong covenants, gives investors greater control and also dampens risk. Ultimately, the better we are at acknowledging, evaluating and managing risk, from whichever direction it comes, the greater the chance we have of delivering high quality and sustainable returns for our clients”.

HOLISTIC CREDIT ANALYSIS: FIRST HYDRO First Hydro is a clear example of how an integrated approach should work, and why bond investing demands a bespoke ESG process. First Hydro is part of the Engie group. Engie operate several nuclear and coal power stations and, for many ESG models, that would be enough to screen the company out on a ‘sell first, ask questions later’ basis. But our asset specific approach means that we can look directly at the borrower, kicking the tyres of the company’s operations. In this case, First Hydro generates hydro electric energy and is financed on a stand-alone basis. The bonds they issued were to fund a specific project, and benefit from security over the company’s assets, so if interest or bond principal isn’t paid, we have an enhanced position compared to other creditors. Best of all, because First Hydro isn’t as well-known as its parent, the bonds actually have a higher yield. Adopting an inflexible equity-like approach or using third party ESG systems may well have screened out this bond, robbing portfolios of an attractive and sustainable source of excess returns.

GREEN MAY NOT BE BETTER First Hydro actually stands in stark contrast to so-called ‘Green Bonds’. Foden is clearly less keen on these, concerned that while they can look good at first glance, in certain circumstances, they may be a compromised investment.

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“Conceptually, we are supportive of green bonds raising the profile of environmental issues in fixed income markets. However, the evolution of the green bond sector is, in our view, a classic example of the market meeting an investor need, which is very valid, with a convenient but suboptimal solution. The bonds are typically unsecured and, although funds raised are often for a specific use, corporate cash is released for wider purposes: as we said earlier, once the money has been raised, can we control how it is used? Worst of all, the increased popularity of green bonds means that pricing may not be attractive, with investors effectively paying a premium for convenience. In a number of cases, the green bond from an issuer will offer a lower yield than ‘non-green’ bonds from the same issuer despite the proceeds of both bonds being interchangeable. In these instances it’s hard not to conclude that the green bond is trading at a lower yield due to its ‘better’ branding. Compare this to First Hydro, and similar unlabelled green bonds we favour, that give us proper visibility on the environmental efficacy of our investments without any compromise on bond protections and returns. And that, in short, must be the essence of any sustainable approach to fixed income investing.”

First Hydro is a clear example of how an integrated approach should work

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A FIERY SUMMER IN BRITAIN’S BOARDROOMS Ashley Hamilton Claxton, Head of Responsible Investment, Royal London Asset Management

Whisper it if you dare, but after several years in the spotlight, executive pay is no longer the hottest topic in corporate governance. The most egregious remuneration practices still saw investor dissent and media turmoil during this year’s AGM season, but two things ensured that remuneration wasn’t the only thing fighting for space in the headlines. This was partly down to better governance practices, with plenty of firms consulting shareholders on pay and acting on their feedback when necessary. The key reason however, was that as spring rolled into summer and the weather outside became stifling, a number of boardroom dramas of a very different sort were kindled.

BOARDROOM BATTLES The first sparks were lit at WPP, where after years of engagement with the company over succession planning, we got a chance to see how WPP looked ‘Post-Sorrell’. Steamy rumour, heated exchanges and hushed intrigue might have fuelled the departure of the firm’s founder and CEO, but as investors our primary concern was a smooth transition process while a replacement was appointed. WPP’s internal appointment of a pair of joint COOs to manage the sprawling empire on an interim basis offered it some breathing room. The company has now appointed a permanent CEO, Mark Read who is now tasked with steadying the ship and restoring investor confidence in the struggling ad firm. Even as the dust settled over WPP’s Mayfair headquarters, this febrile atmosphere began to be replicated in a number of further management spats that ignited up and down the FTSE.

Former directors and activist investors teamed up in various combinations in an attempt to oust existing management from the boardrooms. The Board of Russian-focused gold miner Petropavlovsk fell to a shareholder revolt, when two anonymously owned investment vehicles and a cryptocurrency entrepreneur narrowly succeeded in ousting the entire board in favour of three former directors, including a recently departed CEO. Meanwhile at Stobart Group, the company’s former CEO led a failed campaign to install a new Chairman while succeeded in getting himself (albeit briefly) re-elected to the board of the company before once again being dismissed at the company’s AGM. A second failed attempt to evict a director took place weeks later at Premier Foods, with the firm’s CEO barely surviving a fiercely fought attack from a hedge fund.

PAY PERSISTS Although executive pay was not the most interesting or exciting aspect of this year’s AGM season for once, private and public conversations about how (and how much) to pay Britain’s CEOs continues to persist. Some of the highest votes against pay stemmed from compensation plans designed several years ago, where poorly structured legacy plans led to inappropriate awards. Although WPP often tops the list of pay villains, Persimmon, the Yorkshire housebuilder, was the one that caught everyone’s eye this year. At the firm’s general meeting six years ago in October of 2012, 85% of shareholders voted to approve a share plan that allowed for a potentially eye-watering pay-out. Fast forward a few years and Persimmon’s share price, galvanised by the impacts of the government Help to Buy scheme, was set to hand executives a record pay-out.

As recently as the 2017 AGM, while we spoke out in opposition to the plans (and in some cases were commended for it), just 9% of shareholders voted against the firm’s remuneration report. A year on, after a swathe of political attention, media outrage and the resignation of the firm’s Chairman and Chair of the Remuneration Committee, almost half of Persimmon’s shareholders voted against the 2018 remuneration report.

Good governance is top of mind in our smaller companies funds What’s surprising to us is that nothing in the structure of the legacy scheme had changed. Shareholders would have known back in 2012 what they were approving, yet many voted for it anyway. Our approach has been to consistently focus our remuneration analysis on the structure of pay awards and vote against on those grounds. So perhaps it was the glare of outside scrutiny which compelled other shareholders to act and vote against the company’s 2018 pay report, but by that point it was too late.

CODED MESSAGES So where do we go from here? The Financial Reporting Council’s new Corporate Governance Code published in July should hopefully refocus attention on the things that matter the most in governance. The new Code’s focus on corporate culture and the recommendation to consider the views of a wider range of stakeholders will encourage companies to take a more wholesome view. From the requirement for remuneration committees

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to have formal responsibility for the wider workforce remuneration (not just executives), to an explicit provision for the board to monitor culture and state the actions taken where issues are found, these steps should help to drive progress. The new provision for some form of meaningful worker representation at board level (albeit scaled back from earlier proposals) reinforces these requirements. While the old regime had tended to apply the most rigour to the larger names in the index, one of the most important aspects of the new Code was its application to a broader range of companies. Under the new guidance, smaller companies will need to ‘comply or explain’ in accordance with the provisions of the Code. While

ultimately compliance with the Code will remain voluntary, we expect this will start to drive better governance practices down beyond FTSE 350 companies into the small cap market. Smaller companies will be asked to have more independent directors and conduct more regular board effectiveness reviews. Good governance is top of mind in our smaller companies funds, and we are supportive of these changes. A grace period to adapt to the Code is understandable, and engagement with boards over the summer period suggests that many firms are working to incorporate these as soon as practically possible. But in the long run, companies should ensure that they pay more than lip-service to the

proposals, and expect robust engagement and voting from their investors should they fail to act. The lesson to be learned from cases such as WPP, Petropavlovsk, Premier Foods and Stobart is that even at the largest companies, shareholders and their voting rights can have profound impacts. It’s up to investors to use this influence responsibly.

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LIFTING THE LID ON EMERGING MARKETS Tom Johnson, Responsible Investment Analyst

Last year, Royal London Asset Management launched a new fund designed to track the performance of the stock markets in a range of emerging markets. The RL Emerging Markets Equity Tracker Fund represents a next step in RLAM’s ESG integration, as we explicitly chose to benchmark it against an index which considered environmental, social and governance factors as part of its construction. The new fund is arguably the most diverse fund that RLAM has ever launched. Its 400 constituent companies are from over 20 different countries (and are priced in over 20 different currencies) from several different continents. However, underpinning these statistics are real investments in real companies, where the quality of management and the businesses exposure to (and ability to manage) environmental and social risks has helped to differentiate them from their competitors. With that in mind, we thought we’d offer a snapshot of the ESG profiles of some of the companies in the index, and a few which don’t make the cut.

DRIVING CHANGE One firm within the fund is Chinese car manufacturer Geely. The company’s own-brand fleet has a lower emissions profile than local rivals such as Dongfeng and Great Wall, while its portfolio also includes the Volvo brand, which has a pledge to launch only electric or hybrid cars from 2019. This focus on clean technology and its wider quality control procedures have earned it an AA rating on MSCI, placing it in the highest tier of any auto manufacturer. Although the firm’s governance is below average, it ranks fairly favourably within the context of the Chinese market.

By contrast, fellow auto firm Great Wall isn’t currently a constituent of the ESG focused index. The firm most recently hit the headlines thanks to contradictory musings about an acquisition of Fiat Chrysler, but has a chequered history, including a product recall in 2012 following the discovery of asbestos bound into the exhaust gaskets. In addition, labour management remains a risk for the firm, with staff turnover rates said to be higher than industry average, particularly among foreign employees.

SUSTAINABLE BANKING Sberbank, and Russia’s other large banks, are some of the firms which don’t make the cut. Although some investors have recently had success in engaging with Sberbank over its money laundering policies, the commercial arm of the bank is a key lender to Russian metal, mining, oil & gas businesses. The bank itself has very limited disclosures about its own environmental policies and wider mitigation of material environmental and social risks. However, one emerging market bank which features in the fund, and appears as a leader within its field, is Egypt’s Commercial International Bank. CIB has a clear policy on incorporating sustainability into its wider business, and sets out in clear terms how it engages with its wider stakeholders. CIB is in the process of launching a green finance fund, and within its own operations has set publicly disclosed targets for areas such as waste management. In addition, the bank publishes an independently audited sustainability report.

MINING FOR GEMS A company in the business of digging up copper and aluminium might not seem an obvious fit for an ESG index, but some firms like India’s Hindalco are included

in the fund. The firm has published sustainability reports for a number of years and discloses detailed environmental monitoring reports for each of its core mining assets, and market leading disclosures for a range of initiatives, including labour management, a key risk within the sector. An example of how these risks can manifest themselves can be seen at a similar business Vedanta Ltd, which has experienced material losses following the closure of a copper smelter in Tamil Nadu by a local regulator because of alleged environmental violations at the site. Vedanta, which isn’t a constituent of the ESG index, also suffers from a complex ownership structure, with 50% held by a London listed parent and itself holding stakes in other publicly listed companies.

KEEP ON DIGGING Most accept the higher growth potential for emerging markets, and we feel that there is sometimes reluctance given the higher ESG risks, particularly weaker governance and legal systems. Good, sound management is therefore paramount for investors seeking to venture into emerging markets. The ESG filter takes the 1,100 stocks in the wider MSCI index and slims it down to around 400 stocks. Plenty of companies don’t make the grade, but we believe that the result is a higher quality index that will give investors a better risk/return profile. Find out more here.

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YOUR VOICE – RLAM VOTING ON YOUR BEHALF ENGAGEMENT

AUDITORS

We have engaged with 73 companies over the last six months on the following topics:

The collapse of Carillion in January 2018 and issues at Capita again threw auditors and the effectiveness of audits into the spotlight. Neither of these companies were owned actively by Royal London due to historic concerns with the business models and governance. As investors we are reliant on the efficacy and independence of the auditors and their reports, as we do not have direct insight into the day-to-day running of a business. The predominance of the Big Four audit firms has long been of concern and we take a firm stance on auditors exceeding the recommended length of tenure. We will oppose the reelection of any auditors who have exceeded their tenure (absent the assurance of an imminent rotation) or in any other way impact their independence, and have done so on 83 occasions. We will also consider voting against the members of the Audit Committee should this issue persist, or there be concerns with the effectiveness of the audit.

VOTING

DIVERSITY

Remuneration

Topic

No. of interactions

Remuneration

AGM vote

Corporate governance

Strategy & Succession Planning

Energy & Sustainability

Labour

Diversity & Culture

Other

Reputational risks

Total

REMUNERATION A large proportion of our engagement work continues to centre around the issue of executive remuneration – in the last six months we have spoken to thirty individual companies on the topic. We believe that pay should be appropriate to the company’s specific circumstances and strategy and therefore linked to robust performance measures. The majority of this engagement work is conducted prior to a company’s AGM and will cover prospective changes to policies or problematic practices. Many of these interactions result in improvements or changes to policies. A notable example was Severn Trent who scaled back their initial proposals following our feedback. Bovis Homes also noticeably improved their approach following investor feedback. Other examples this year were United Utilities, Charter Court, De La Rue, Ferguson, RELX, WH Smith and Experian. Despite this level of engagement, we retain a rigorous approach to voting on remuneration and only supported 67% of pay proposals.

We engage both individually and collectively regarding diversity. We are active members of the 30% Club Investor Group, and have recently co-signed letters to five companies requesting group engagement meetings to address the gender imbalance on the board, executive team and throughout the workforce. At virtually every ESG meeting held with a company we will ask what the company is doing to address diversity and inclusion. Among others, we have spoken to Prudential, Dunelm, SEGRO, Sophos and Glencore about this. Our voting policy was also strengthened in this regard in January 2018 and we have voted either against or abstained on the Nomination Committee Chairmen at 95 companies on the grounds that they do not meet a 25%

Total number of meetings Total number of proposals

800 11,532

Overall voting Votes for Abstain Votes against Take no action*

Votes for Abstain Votes against Take no action*

10,308 150 1,016 58

717 25 318 12

* We endeavour to vote all positions but in markets subject to shareblocking we may elect not to vote due to the implications of our shares being temporarily blocked from trading.

gender diversity threshold. Where the companies are actively held, we have also issued letters to the board setting out our concerns. In a number of instances this has led to the appointment of directors immediately following engagement and/or voting.

NOTES

1 If you’re interested in the work RLAM has done on water companies, see our paper Assessing ESG performance across the UK water sector and its impact on credit portfolios. 2 For more information on this work, see our paper Credit & ESG analysis: energy efficiency and secured commercial property bonds. The views expressed are the author’s own and do not constitute investment advice. Issued by Royal London Asset Management Limited, Firm Registration Number: 141665, registered in England and Wales number 2244297; Royal London Unit Trust Managers Limited, Firm Registration Number: 144037, registered in England and Wales number 2372439; RLUM Limited, Firm Registration Number: 144032, registered in England and Wales number 2369965. All of these companies are authorised and regulated by the Financial Conduct Authority. Royal London Asset Management Bond Funds Plc, an umbrella company with segregated liability between sub-funds, authorised and regulated by the Central Bank of Ireland, registered in Ireland number 364259. Registered office: 70 Sir John Rogerson’s Quay, Dublin 2, Ireland. All of these companies are subsidiaries of The Royal London Mutual Insurance Society Limited, registered in England and Wales number 99064. Registered Office: 55 Gracechurch Street, London, EC3V 0RL. The Royal London Mutual Insurance Society Limited is authorised by the Prudential Regulation Authority and regulated by the Financial Conduct Authority and the Prudential Regulation Authority. The Royal London Mutual Insurance Society Limited is on the Financial Services Register, registration number 117672. Registered in England and Wales number 99064. Ref: BR RLAM P1 0038

Contact us For further information about our responsible investment capabilities, please contact: Royal London Asset Management 55 Gracechurch Street London EC3V 0RL 020 7506 6500 communications@rlam.co.uk www.rlam.co.uk Ashley Hamilton Claxton Head of Responsible Investment Tom Johnson Responsible Investment Analyst Victoria McArdle Sustainable Investment Analyst Sophie Johnson Corporate Governance Analyst

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