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LocalTapiola Asset Management Ltd

PRI reporting framework 2017

Basic Information [OO 01 - 09] Gateway asset class implementation indicators [OO 10 - 12]

Objectives and strategies [SG 05 - 06] Governance and human resources [SG 07 - 08] Promoting responsible investment [SG 09 - 11] Implementation not in other modules [SG 12 - 16] Innovation [SG 17]

Indirect – Manager Selection, Appointment and Monitoring

Overview [SAM 01 - 02] Listed Equity and Fixed Income Strategies [SAM 03 - 04] Selection [SAM 05 - 06] Appointment [SAM 07.1 - 07.2-5] Monitoring [SAM 08 - 10] Outputs and outcomes [SAM 11 - 12] Communication [SAM 13]

Direct - Listed Equity Incorporation

Overview [LEI 01 - 02] ESG incorporation in actively managed listed equities [LEI 03 - 12] Implementation processes [LEI 03 - 12] (C) Implementation: Integration of ESG issues [LEI 10 - 12] Outputs and outcomes [LEI 14 - 16] Communication [LEI 17]

Direct - Listed Equity Active Ownership

Engagement [LEA 01 - 16] Overview [LEA 01 - 02] Process [LEA 03 - 10] Process for engagements run internally [LEA 03 - 04] Process for engagements conducted via collaborations [LEA 05 - 06] General processes for all three groups of engagers [LEA 09 - 10] Outputs and outcomes [LEA 11 - 15] Communication [LEA 16] (Proxy) voting and shareholder resolutions [LEA 17 - 27] Overview [LEA 17] Process [LEA 18 - 22] Outputs and outcomes [LEA 23 - 26] Communication [LEA 27]

Direct - Fixed Income

Overview [FI 01 - 03] ESG incorporation in actively managed fixed income [FI 04 - 16] Implementation processes [FI 04 - 06] (C) Implementation: Integration [FI 14 - 16] Fixed income - Engagement [FI 18 - 20] Outputs and outcomes [FI 21 - 22] Communication [FI 23]

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You are in Strategy and Governance » Investment policy

Investment policy

SG 01. RI policy and coverage

New selection options have been added to this indicator. Please review your prefilled responses carefully.

01.1. Indicate if you have an investment policy that covers your responsible investment approach.

Yes

01.2. Indicate the components/types and coverage of your policy.

Select all that apply

Policy components/types	Coverage by AUM
Policy setting out your overall approach Formalised guidelines on environmental factors Formalised guidelines on social factors Formalised guidelines on corporate governance factors Asset class-specific RI guidelines Sector specific RI guidelines Screening / exclusions policy Engagement policy (Proxy) voting policy Other, specify (1) Other, specify(2)	Applicable policies cover all AUM Applicable policies cover a majority of AUM Applicable policies cover a minority of AUM

01.4. Indicate what norms you have used to develop your investment policy that covers your responsible investment approach.

UN Global Compact Principles

UN Guiding Principles on Business and Human Rights

Universal Declaration of Human Rights

International Bill of Human Rights

International Labour Organization Conventions

United Nations Convention Against Corruption

OECD Guidelines for Multinational Enterprises

Other, specify (1)

Other, specify (2)

Other, specify (3)

None of the above

01.6. Provide a brief description of the key elements, any variations or exceptions to your investment policy that covers your responsible investment approach. [Optional]

In quantitative strategies we don't conduct any in-house ESG analysis of the companies but instead take into account an ESG rating provided by a third party service provider, as one parameter of a total of five parameters in the model.

As to external managers, we score the managers on the basis of their RI policies and practices but don't conduct analysis on the underlying investments or aim to influence their investment decisions.

SG 02. Publicly available RI policy or guidance documents

New selection options have been added to this indicator. Please review your prefilled responses carefully.

02.1. Indicate which of your investment policy documents (if any) are publicly available. Provide a URL and an attachment of the document.

Policy setting out your overall approach

URL/Attachment

URL

URL https://www.lahitapiola.fi/henkilo/sijoitukset-ja-varainhoito/kokemus-nakemys-menestys

Attachment (will be made public)

Formalised guidelines on environmental factors

Formalised guidelines on social factors

Formalised guidelines on corporate governance factors

Asset class-specific RI guidelines

URL/Attachment

URL

URL http://public.egate.fi/lahitapiola/lahitapiola/fi/tiedostot/174703/

Attachment (will be made public)

Engagement policy

URL/Attachment

URL

URL https://www.lahitapiola.fi/henkilo/sijoitukset-ja-varainhoito/vastuullinen-sijoittaminen-varainhoidossa/julkaisut

Attachment (will be made public)

(Proxy) voting policy

URL/Attachment

URL

URL http://public.egate.fi/lahitapiola/lahitapiola/fi/tiedostot/125138/

Attachment (will be made public)

We do not publicly disclose our investment policy documents

02.4. Additional information [Optional].

Our RI policy covers all the aspects that we have mentioned above. It is publicly available on our web-site.

Guidelines on environmental, social and governance issues are included in our in-house ESG -analysis tool, and are not publicly available.

As we are an asset manager (vs asset owner) we don't have our own (proxy) voting policy. We adhere to our clients' policy if voting on their behalf, and to LocalTapiola Mutual funds' active ownership policy, when voting on behalf of the funds. The latter is publicly available on our website.

SG 03. Conflicts of interest

03.1. Indicate if your organisation has a policy on managing potential conflicts of interest in the investment process.

Yes

03.2. Describe your policy on managing potential conflicts of interest in the investment process.

LocalTapiola Asset Management's portfolio managers do not take own positions for our own accounts. Hence we only make investment decisions in order to benefit our clients. We have a written policy that determines the equal treatment of clients.

At companies' annual meetings, we may vote on behalf of clients if requested to do so. However, if our client wants to raise an issue that is contrary to our view, we ask the client to proceed in the matter on their own accord.

Local Asset Management's operations are conducted separately from the rest of the insurance group. Our company's board is aware of and oversees any board memberships by the staff. In case of conflicts of interest, a person in question will recuse him or herself regarding the company in question.

03.3. Additional information. [Optional]

SG 04. Identifying incidents occurring within portfolios (Private)

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