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(C) Implementation: Integration of ESG factors

LEI 08. Review ESG issues while researching companies/sectors

08.1. Indicate the ESG factors you systematically research as part of your investment analysis and the proportion of actively managed listed equity portfolios that is impacted by this analysis.

ESG issues	Proportion impacted by analysis
Environmental	Environmental <10% 10-50% 51-90% >90%
Social	Social <10% 10-50% 51-90% >90%
Corporate Governance	Corporate Governance <10% 10-50% 51-90% >90%

08.2. Additional information. [Optional]

The review of sustainability issues is part of the mandates of the portfolio managers. In addition the Advisory group on Sustainability address those issues in their meetings. The Sustainbility team works on a daily basis with different issues.

LEI 09. Processes to ensure integration is based on robust analysis

09.1. Indicate which processes your organisation uses to ensure ESG integration is based on a robust analysis.

Comprehensive ESG research is undertaken or sourced to determine companies’ activities and products

Companies are given the opportunity by you or your research provider to review ESG research on them and correct inaccuracies

Third-party ESG ratings are updated regularly.

A periodic review of the internal research is carried out

Structured, regular ESG specific meetings between responsible investment staff and the fund manager or within the investments team

ESG risk profile of a portfolio against benchmark

Analysis of the impact of ESG factors on investment risk and return performance

Other, specify

          The service providers AP3 use have the resources to ensure that data and analysis is reliable and robust. The Council on Ethics also investigate.

None of the above

09.2. Indicate the proportion of your actively managed listed equity portfolio that is subject to comprehensive ESG research as part your integration strategy.

<10%

10-50%

51-90%

>90%

09.3. Indicate how frequently third party ESG ratings that inform your ESG integration strategy are updated.

Quarterly or more frequently

Bi-Annually

Annually

Less frequently than annually

09.5. Describe how ESG information is held and used by your portfolio managers.

ESG information is held within centralised databases or tools and it is accessible by all relevant staff

ESG information or analysis is a standard section or aspect of all company research notes or industry/sector analysis generated by investment staff

Systematic records are kept that capture how ESG information and research was incorporated into investment decisions

Other, specify

None of the above

09.6. Additional information.[Optional]

The managers have access to ESG Manager including Carbon Metrics, Bloomberg, Trucost, GES/Sustainalytics data/information is also used. Other souces can be made available if asked for. Sustainability issues are expanding in the company research and are a natural part of the analysis.

Increasingly ESG issues are incorporated in external sell side analysis.

Companies increasingly also include sustainability issues in their meetings and presentations as a strategic and or risk point on the agenda.

LEI 10. Aspects of analysis ESG information is integrated into (Private)

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PRI reporting framework 2019