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VanEck

PRI reporting framework 2019

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

Strategy and Governance

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] Communication [SG 19]

Direct - Listed Equity Incorporation

Direct - Listed Equity Active Ownership

Overview [LEA 01] Engagement [LEA 02 - 08] Outputs and outcomes [LEA 09 - 11] (Proxy) voting and shareholder resolutions [LEA 12 - 21]

Direct - Fixed Income

Direct - Hedge Funds

Confidence building measures

Confidence building measures [CM1 01 - 07]

Export Public Responses

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

Fiduciary (or equivalent) duties

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

01.3. Indicate if the investment policy covers any of the following

Your organisation’s definition of ESG and/or responsible investment and it’s relation to investments

Your investment objectives that take ESG factors/real economy influence into account

Time horizon of your investment

Governance structure of organisational ESG responsibilities

ESG incorporation approaches

Active ownership approaches

Reporting

Climate change

Understanding and incorporating client / beneficiary sustainability preferences

Other RI considerations, specify (1)

Other RI considerations, specify (2)

01.4. Describe your organisation’s investment principles and overall investment strategy, interpretation of fiduciary (or equivalent) duties,and how they consider ESG factors and real economy impact.

As a fiduciary, VanEck (the “Firm”) is expected to act in the best interests of its clients. Irrespective of the account relationship, VanEck’s fiduciary obligation applies in every aspect of its dealings with its clients.

VanEck’s approach to responsible investment incorporates environmental, social, and governance (“ESG”) responsibilities into its active investment process. VanEck views ESG factors as fundamental and integral components of its active investment process and is committed to incorporating them, where possible, into its active investment analysis, decision making, and ownership policies.

VanEck believes that it is in the interest of its clients to consider these factors when making an investment decision. It also believes that a strong or genuinely improving ESG record should translate into a company’s differentiated financial performance and may have an impact on valuation. It further believes that companies exhibiting strong ESG practices will more likely be successful over the medium to long term.

VanEck believes, in addition, that an essential part of its responsibility to clients is not only to encourage change that can enhance, protect, and provide opportunities for long-term returns for shareholders, but also to seek to mitigate associated risks.

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

01.6. Additional information [Optional].

I confirm I have read and understood the Accountability tab for SG 01 I confirm I have read and understood the Accountability tab for SG 01

SG 01 CC. Climate risk (Not Applicable)

SG 02. Publicly available RI policy or guidance documents (Not Completed)

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.

As a fiduciary, VanEck (the “Firm") is expected to act in the best interests of its clients. Irrespective of the account relationship, VanEck’s fiduciary obligation applies in every aspect of its dealings with its clients. VanEck has adopted policies and procedures for the identification and management of conflicts of interest to: (i) identify actions, transactions, circumstances or relationships that are or could potentially be deemed or appear to be a conflict between the interests of the Firm or its employees and those of its clients; (ii) to assess the impact of such conflict on its clients; (iii) devise policies, procedures and controls reasonably designed to address a conflict in a manner that is fair and equitable and does not disadvantage a client relative to the Firm, employees or other clients; and (iv) makes disclosure of those conflicts in accordance with applicable law to its clients.

VanEck’s Code of Ethics addresses conflicts of interest. The Code of Ethics imposes restrictions on certain securities transactions to help avoid conflicts of interests. In addition, real or potential conflicts of interest must be disclosed to the Compliance Department, including those resulting from an employee’s business or personal relationships.

03.3. Additional information. [Optional]

SG 04. Identifying incidents occurring within portfolios (Not Completed)

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