It is the investment team's responsibility to ensure compliance with the RI policy. This is monitored by the CIO with assistance from a third party ESG research provider that conducts an annual review of the portfolio to ensure the investee companies pass our negative screen. We also conduct reviews of individual securities on an adhoc basis if there are concerns about the whether a company will pass the negative screen.
The CIO monitors all mandate breaches, including breaches of the negative ethical screen applied by the International equity strategies. If breaches occur they are discussed between the CIO and the relevant team and corrective action taken. Persistent breaches or unresolved breaches are included in the Breach Register which is submitted to the Compliance Committee. All Compliance Committee papers are then submitted to the Responsible Entity boards.