At EVC, our affiliates’ approach to responsible investing is both flexible and evolving. Portfolio managers and analysts seek to understand the potential impacts of how issuers manage ESG risks and opportunities using both proprietary and third-party research. Because these risks and opportunities vary across industries, geographies and business models, we believe that maintaining a focus on financial materiality is critical to effective ESG research.

Our governance structure for incorporating ESG insights into investment decisions and portfolio construction has two tiers. The first level is the Responsible Investing Leadership Team, which includes selected equity and fixed income chief investment officers from various affiliates, Calvert’s chief executive officer and other senior investment leaders. The Responsible Investing Leadership Team meets quarterly to discuss emerging developments and to track progress as it relates to responsible investing and ESG integration.

The second tier of the governance structure is the Research Working Group, whose membership consists of selected analysts and portfolio managers from our affiliates representing diverse investment strategies and multiple office locations across the globe. The group meets monthly to discuss new ESG information and best practices, and reports to the Responsible Investing Leadership Team at least quarterly.

Calvert: During the reporting period, the Boards of Trustees of the Calvert Funds (the "Funds") have oversight of Calvert, the adviser who implements the principles on behalf of the Funds. Calvert's President and CEO had ultimate oversight over Calvert's responsible investment activities alongside the Responsible Research Review Committee, of which he is a member. ESG research analysts, led by the Director of ESG Research, conduct ESG research designed to identify and measure financially material ESG risk exposures, based upon the Calvert Principles for Responsible Investment as a framework.

Parametric: Investment decisions are made as a result of feedback from the investment team, including portfolio managers, investment strategists, research analysts and traders. The firm's investment strategists and research team are responsible for creating and maintaining the quantitative systems and tools for use across the firm. These rules govern how the portfolios are constructed and managed, and are the implementation rules which dictate the actions of the portfolio management team. The Director of Responsible Investing is the strategist for the Parametric Responsible Investing product suite and guides the research agenda for these strategies under the direction of Chief Investment Officer and Head of Investment Management.

Eaton Vance Management: offers equity, income, alternative and multi-asset strategies that may integrate consideration of financially material ESG factors into fundamental research processes seeking to enhance each portfolio's risk/return profile. Their approach to responsible investing is both flexible and evolving. EVM's portfolio managers and analysts seek to understand the potential impacts of how issuers manage ESG risks and opportunities using both proprietary and third-party research. Because these risks and opportunities vary across industries, geographies and business models, we believe that maintaining a focus on financial materiality is necessary to effective responsible investing.

Atlanta Capital: The President and Chief Compliance Officer of Atlanta Capital has ultimate oversight over all investment activities, including integration of Calvert ESG research into the investment process where applicable. To support the effort, the Compliance Director and team ensure that both permitted and prohibited securities are correctly coded into the trade order management system where prohibited securities are blocked from purchase on a pre-trade basis and permitted securities are allowed to be purchased. The Portfolio Management team and Investment Specialist review and monitor securities as well.

The Portfolio Management team and Investment Specialist review and monitor holdings for changes in investment thesis or ESG profile and take action as necessary.

The number above includes:

29 dedicated Calvert research associates

7 Parametric employees dedicated to responsible investing.

Please note there are approximately 200 investment professional employees that have dual roles across EVM and Calver who are not consider ‘dedicated’ as they have other non-responsible investment responsibilities.

Calvert:

Compensation of Calvert's portfolio managers and other investment professionals has three primary components: (1) a base salary, (2) an annual cash bonus, and (3) annual stock-based compensation consisting of options to purchase shares of EVC's nonvoting common stock and restricted shares of EVC's nonvoting common stock. Calvert's investment professionals also receive certain retirement, insurance and other benefits that are broadly available to Calvert's employees. Compensation of Calvert's investment professionals is primarliy reviewed on an annual basis. Cash bonuses, stock-based compensation awards, and adjustments in base salary are typically paid or put into effect at or shortly after the October 31st fiscal year end of EVC.

Specific to the Calvert ESG Analysts, annual bonus awards may include consideration of: 1) the quality of ESG research conducted, based on the ability to identify financially material ESG factors for the industry sub sectors and companies assigned to the analyst; 2) demonstrated knowledge of industry sub sectors and companies; 3) demonstrated knowledge of key ESG issues and the relevant Key Performance Indicators; 4) the impact of ESG factors within those sectors/industries, and; 5) the overall performance of the associated funds/strategies.

Parametric:

The compensation structure for Responsible Investing-related employees does not differ from compensation for employees not involved in Responsible Investing.

Parametric believes that its compensation packages, which are described below, are adequate to attract and retain high-caliber professional employees. Please note that compensation for investment professionals is not based directly on investment performance or assets managed, but rather on the overall performance of responsibilities. In this way, the interests of portfolio managers are aligned with the interests of investors without providing incentive to take undue or insufficient investment risk. It also removes a potential motivation for fraud. Violations of Parametric's policies would be a contributing factor when evaluating an employee's discretionary bonus.

Eaton Vance Management:

Compensation of portfolio managers and other investment professionals at EVM has three primary components: (1) a base salary, (2) an annual cash bonus, and (3) annual stock-based compensation consisting of options to purchase shares of Eaton Vance Corp.'s ("EVC") nonvoting common stock and restricted shares of EVC's nonvoting common stock. EVM's investment professionals also receive certain retirement, insurance and other benefits that are broadly available to EVM's employees. Compensation of EVM's investment professionals is reviewed primarily on an annual basis. Cash bonuses, stock-based compensation awards, and adjustments in base salary are typically paid or put into effect at or shortly after the October 31st fiscal year end of EVC.

EVM seeks to compensate its credit and equity analysts based primarily on the quality of investment recommendations made and contribution to the performance of managed funds and accounts. Performance measurement is normally based on periods ending on the September 30th preceding EVC fiscal year ends. Consideration is also given to the quality of oral and written communication and measures of overall effectiveness as determined by the analyst's department head and/or portfolio managers working with the analyst. For analysts who also manage portfolios or have other duties, compensation reflects responsibilities and performance on an overall basis. Contribution and measures of performance are viewed within a multi-year context with the primary emphasis normally placed on three year performance.

Atlanta Capital:

Compensation of all Atlanta Capital employees including investment professionals is reviewed on an annual basis and has three primary components: (1) a base salary, (2) an annual cash bonus, and (3) annual stock-based compensation consisting of options to purchase shares of EVC's non-voting common stock and/or restricted shares of EVC's non-voting common stock. Certain senior executives and investment professionals are eligible to receive profit participation ownership interests in Atlanta Capital based entities. All employees also receive certain retirement, insurance and other benefits. Cash bonuses, stock-based compensation awards, adjustments in base salary and retirement plan contributions are typically paid or put into effect at or shortly after the October 31st each year. The long term portions of compensation including options/restricted stock awards and Atlanta Capital ownership interests are subject to vesting over a five year period.