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Wellington Management Company LLP

PRI reporting framework 2018

Basic information [OO 01 - 09] Asset class implementation gateway indicators [OO 10 - 12] Peering questions [OO LE 01 - INF 03]

Strategy and Governance

Investment policy [SG 01 - 04] Objectives and strategies [SG 05 - 06] Governance and human resources [SG 07 - 08] Promoting responsible investment [SG 09 - 11] Outsourcing to fiduciary managers and investment consultants [SG 12] ESG issues in asset allocation [SG 13 - 15] Innovation [SG 18] Communication [SG 19]

Direct - Listed Equity Incorporation

ESG incorporation in actively managed listed equities [LEI 01 - 10] Implementation processes [LEI 01 - 10] (A) Implementation: Screening [LEI 04 - 06] (B) Implementation: Thematic [LEI 07] (C) Implementation: Integration of ESG issues [LEI 08 - 10] Outputs and outcomes [LEI 12 - 14]

Direct - Listed Equity Active Ownership

Engagement [LEA 01 - 14] Overview [LEA 01 - 02] Process [LEA 03 - 10] Process for engagements run internally [LEA 03 - 04] General processes for all three groups of engagers [LEA 09 - 10] Outputs and outcomes [LEA 11 - 14] (Proxy) voting and shareholder resolutions [LEA 15 - 24] Overview [LEA 15] Process [LEA 16 - 20] Outputs and outcomes [LEA 21 - 24]

Direct - Fixed Income

ESG incorporation in actively managed fixed income [FI 01 - 13] Implementation processes [FI 01 - 03] (A) Implementation: Screening [FI 04 - 07] (C) Implementation: Integration [FI 11 - 13] Fixed income - Engagement [FI 15 - 17] Outputs and outcomes [FI 18 - 19]

Assurance

Assurance [CM1 01.1 - 01.7]

Export Public Responses

You are in Strategy and Governance » Asset class implementation not reported in other modules

Asset class implementation not reported in other modules

SG 16. ESG issues for internally managed assets not reported in framework

Describe how you address ESG issues for internally managed assets for which a specific PRI asset class module has yet to be developed or for which you are not required to report because your assets are below the minimum threshold.

Asset Class	Describe what processes are in place and the outputs or outcomes achieved
Hedge funds - DDQ	Select whether you have responded to the PRI Hedge Fund DDQ Yes No
Hedge funds	Within our hedge funds, we consider ESG criteria as one set of factors among many that should be weighted appropriately to inform investment decision making. We view ESG analysis and integration as both return enhancing and risk mitigating. Similar to ESG integration within our long only portfolios, engagement also plays a critical role in helping to identify, understand, and appropriately consider ESG risks.
Other (1) [as defined in Organisational Overview module]	At Wellington Management, within our Global Multi-Asset Strategies, we consider environmental, social, and corporate governance (ESG) criteria as one set of factors among many that should be weighed appropriately to inform investment decision making. We view ESG analysis and integration as both return enhancing and risk mitigating.

16.2. Additional information [Optional].

SG 17. ESG issues for externally managed assets not reported in framework (Not Applicable)