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Vontobel Holding AG

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

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] Asset class implementation not reported in other modules [SG 16 - 17] 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 factors [LEI 08 - 10] Outputs and outcomes [LEI 12 - 13]

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

ESG incorporation in actively managed fixed income [FI 01 - 12] Implementation processes [FI 01 - 03] (A) Implementation: Screening [FI 04 - 06] Fixed income - Engagement [FI 14 - 16] Outputs and outcomes [FI 17 - 18]

Confidence building measures

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Confidence building measures

CM1 01. Assurance, verification, or review

01.1. Indicate whether the reported information you have provided for your PRI Transparency Report this year has undergone:

Third party assurance over selected responses from this year’s PRI Transparency Report

Third party assurance over data points from other sources that have subsequently been used in your PRI responses this year

Third party assurance or audit of the correct implementation of RI processes (that have been reported to the PRI this year)

Internal audit of the correct implementation of RI processes and/or accuracy of RI data (that have been reported to the PRI this year)

Internal verification of responses before submission to the PRI (e.g. by the CEO or the board)

Whole PRI Transparency Report has been internally verified

Selected data has been internally verified

Other, specify

None of the above

01.2. Additional information [OPTIONAL]

CM1 02. Assurance of last year's PRI data

02.1. We undertook third party assurance on last year’s PRI Transparency Report

Whole PRI Transparency Report was assured last year

Selected data was assured in last year’s PRI Transparency Report

We did not assure last year's PRI Transparency report

None of the above, we were in our preparation year and did not report last year.

02.3. Additional information [OPTIONAL]

CM1 03. Other confidence building measures

03.1. We undertake confidence building measures that are unspecific to the data contained in our PRI Transparency Report:

We adhere to an RI certification or labelling scheme

03.2. Which scheme?

National SRI label based on the EUROSIF Transparency guidelines

% of total AUM the scheme applies

< 25%

25-50 %

50-70 %

>75 %

B-corporation

UK Stewardship code

GRESB

Commodity type label (e.g. BCI)

Social label

Climate label

RIAA

Other

We carry out independent/third party assurance over a whole public report (such as a sustainability report) extracts of which are included in this year’s PRI Transparency Report

ESG audit of holdings

03.4. Describe the process of external/third party ESG audit of holdings, including which data has been assured.

An internal ESG auditor otherwise not involved in the investment process checks all ESG minimum standard frameworks of the financial analysts. The person discusses potential gaps or rating differences with them and challenges their assessment. ESG minimum standard frameworks are then adapted by the financial analysts.

Other, specify

None of the above

03.5. Additional information [OPTIONAL]

CM1 04. Assurance of this year's PRI data

04.1. Do you plan to conduct third party assurance of this year's PRI Transparency report?

Whole PRI Transparency Report will be assured

Selected data will be assured

We do not plan to assure this year's PRI Transparency report

04.3. Additional information [OPTIONAL]

CM1 05. External assurance (Not Applicable)

CM1 06. Assurance or internal audit (Not Applicable)

CM1 07. Internal verification

07.1. Indicate who has reviewed/verified internally the whole - or selected data of the - PRI Transparency Report . and if this applies to selected data please specify what data was reviewed

Who has conducted the verification

CEO or other Chief-Level staff

The Board

Investment Committee

Compliance Function

RI/ESG Team

Investment Teams

Legal Department

Other (specify)

specify

          Corporate Sustainability Management

07.2. Additional information [OPTIONAL]

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