We regularly approach companies to obtain additional information to assist our analysis of their environmental and social impacts and management of those impacts. This includes approaching companies to confirm specific analysis and conclusions in important cases. However, we do not give companies the opportunity to review our ESG research on them and correct inaccuracies in all cases. Some of our external research and data providers do provide details of their analysis to companies which gives them the opportunity to correct inaccuracies.

We conduct a periodic review of our company ethical assessments every 2 years. Reviews will occur more frequently where significant ESG incidents occur. If an ESG incident is identified or the activities or circumstances of an investee company changes such that the company's activities may breach a principle of our Ethical Charter, our ethics team will consult with the investment analyst and investigate and assess the significance of the breach (including its impact on the ethical assessment of the company under the Charter) and the prospects for engagement with the company to take action which would remedy the breach.

Our external ESG research provider updates their company ESG ratings and other ESG data annually or more frequently in response to significant incidents.

As all our listed equities are internally managed, there are systems and procedures in place to avoid breaches of fund screening criteria. The CIO only approves a limit for a company after it is assessed for alignment with the Ethical Charter. Investments may only be made once the limit is approved. The spreadsheet which records the investment limits is linked to our spreadsheet record of companies’ ethical alignment status. This enables automated verification that all companies with limits meet our screening criteria.

If we identified that an investment had been made without the required ethical assessment, then either:

- the investment would be sold as soon as practical; or

- if there is a reasonable prospect that the investment would be assessed as investable under the Ethical Charter, we may conduct an assessment of the investment as soon as practical. If the investment was approved under the Charter it could be retained; if it was not approved it would be sold as soon as practical.

Where an investment has passed our ethical assessment process but new information emerges that a company's activities may breach a principle of our Ethical Charter, our ethics team will consult with the investment analyst and investigate and assess the significance of the breach (including its impact on the ethical assessment of the company under the Charter) and the prospects for engagement with the company to take action which would remedy the breach. If the issue cannot be resolved and is sufficiently serious we will divest.