The Investment Policy Committee, consisting of the most senior investment officers of the firm including the CEO, provides the overarching ESG framework for research and strategy implementation conducted by analysts and portfolio managers. Operating under the guidance of the Investment Policy Committee, the various research groups apply ESG factors into their analysis based on established firm criteria and client guidelines. Implementation is overseen by each strategy group and multiple compliance checks are performed prior to the inclusion of any security into a client portfolio. Furthermore, additional compliance reviews are conducted post-trade and on an ongoing basis to ensure adherence to guidelines. If violations of investment guidelines occur, they are ultimately reported to the Investment Policy Committee.