Our investment process integrates the PIIF principles within fund due-diligence, and we actively promote adoption of the PIIF principles by our external investment manager partners. Inclusive Finance is part of TIAA's Social Impact Investment Portfolio. The General Account's Social Investment Program embodies our endeavor to direct capital toward quality investment opportunities-consistent with the General Account's overall investment strategy and risk-adjusted return expectations-that also create measurable social outcomes. Tracing its roots to the mid-1980s, the program has $1.8 billion in total commitments as of December 31, 2019. The portfolio's goal is to invest in sectors overlooked or underpopulated by mainstream investors and facing capital gaps.

As part of our due-diligence process we evaluate the investment manager's investment strategy with respect to target investee characteristics to ensure that these include financial institutions with the ability to offer a range of products suitable to underserved communities. Further we conduct detail studies of existing investments and pipeline companies to ascertain diversity of products made available to low-income individuals and communities.

Client protection plays a very important role in our due-diligence process and specifically we evaluate the manager's process with respect to investing in companies that place important on:

- Leveraging credit bureau information (where available) to confirm if the client has additional loans outstanding and ensuring that there is training provided to employees on avoiding over-indebtedness.

- Thorough and appropriate credit underwriting processes with good oversight.

- Product and pricing transparency through educating clients on the process and rules for working with the institution. In addition, since most of the investment managers we work with are PIIF signatories, they encourage their investees to endorse Smart Campaign's Client Protection Principles.

Fair treatment of clients and transparency of products and services is an area that we evaluate through our due-diligence process. Some aspects of our evaluation include:

- Client awareness of the process to file a complaint against a loan officer or branch manager in the event of an issue arising.

- How interest rates, terms and conditions for products are explained to clients, including the simplicity or complex nature of the actual loan agreements.

- How efficiently loans are serviced including time taken for loan application, underwriting and disbursement.

We conduct an evaluation of ESG at the manager level and specifically focus on the governance at the fund level. This includes evaluation of the investment committee, advisory board, conflict committee and audit committee to ensure sufficient independence and expertise. Evaluation of governance at the investee level includes some of the same factors but also takes into account the manager's involvement in the board, voting and other shareholder rights. Further, we review any and all environmental and social guidelines for loans made to individuals and small businesses at the investee level (as put in place by the manager).

We promote transparency for the manager as well as investee's. In the case of the manager it includes review of reporting for of voluntary principles like the PIIF, and regular financial and social reporting in line with industry best practices. In the case of investees we encourage voluntary reporting of indicators to the Microfinance Information Exchange (MIX) in particular.

We place great importance on long-term sustainability of the inclusive finance sector. To that end our evaluation takes into account how investment managers participate on the boards of investees to influence matters like growth of business, achieving scale, balancing the needs to current clients versus new client acquisition, cost of capital, timelines for realizing return and other related topics. In our view, inclusive finance practices from country to country will inevitably vary and so will interest rates, and expectation of risk-adjusted return. Our evaluation strives to identify those investment managers that place top priority on the sustainability of the investee and the interests of its customers.

A Nuveen representative has served on the PIIF Steering Committee between 2011 and 2016, and continues to provide leadership and support to its efforts in harmonizing investor standards in the sector. This includes recruiting new signatories to the PIIF, sharing best practices with investors about the value of the principles through participation in discussions and panels at industry conferences and also through ongoing engagement with co-investors, the PRI Secretariat and other signatories to ensure that the principles continue to reflect current industry needs.