Our company was a pioneer of corporate engagement in the Canadian market. Our engagement program has been in place for two decades and we have long-established and highly-experienced internal corporate engagement capacity. Undertaking our own engagement allows for better integration between our company research and evaluations process, our corporate dialogues, our proxy voting and our public policy work; it enables rapid response to emerging issues; and it ensures that our engagement efforts remain linked to our portfolio exposure. We believe that by conducting our own engagement as a shareholder, whether individually or in collaborations, we may better focus on how our dialogue can contribute to company value.

That said, we have long engaged the Canadian Coalition for Good Governance to explore how its well-established program of corporate governance engagement with Canadian corporate boards could enhance input and participation from members, and integrate questions relating to the governance of environmental and social issues.

We do on occasion engage companies in collaboration with our sub-advisors. In those situations we prioritize the engagement targets based on a combination of our regular factors (e.g. materiality of the issues) but with a greater focus on the pre-existing relationships of the sub-advisor and the geography of the companies. We share the engagement duties once the companies have been identified.

Note that for some sign-on activities we may have an engagement objective defined, but depending on the level of participation we may not track performance against these objectives in the same way we do for engagements where we are the lead or are acting solo.

As noted previously, for some sign-on activities we do not follow up and monitor progress in the same manner as we do for engagements where we are the lead or engaging solo. This is a prioritization we undertake to ensure that we maximize the outcomes from the engagements where we are spending the most time and effort.

We continually assess the progress of our engagements to determine if an escalation strategy is required. We may undertake several escalations at once - for example filing a shareholder resolution and voting against key directors. In situations where we have exhausted our options for influencing the company, and do not see any reasonable chance of our key concerns being addressed, we will divest of the company. At that point we follow a process that determines when the company can be considered for eligibility again. This includes a combination of factors that must be present, including the resolution of the key issue of concern; change in key management/leadership at the company; and the passing of a "cooling off" period of up to 3 years depending on the severity of the issue.

We believe that a credible engagement strategy must have the ability to divest if there is no reasonable chance of engagement success. However, we also believe that in order for companies to be incented to respond to engagement they must be able to make their way back into the portfolio as well.

Several categories of engagement within our program are derived from the results of our internal ESG company evaluations program. We undertake tactical dialogues in response to emerging risks and opportunities: these include companies identified through our evaluations process where there are concerns about lack of disclosure or effectiveness of mitigation of key sector ESG risks that could threaten company value, as well as companies currently facing major ESG challenges that have been identified through our Management Breach Investigation and/or OECD Due Diligence processes. ESG company evaluations and information relating to engagement is collected within a single database.

Our internal corporate engagement staff share annual plans and quarterly updates on all corporate engagement with both internal portfolio management colleagues and external portfolio managers. In the case of some of our external portfolio managers who have internal engagement capacity, we develop an engagement strategy for the portfolio companies together and work collaboratively on dialogues.

In the context of our OECD Due Diligence process, we reach out to external portfolio managers where portfolio companies have been identified as being associated with severe adverse impacts, to share insights and determine whether we need to engage directly.

We maintain records on dialogue topics, engagement activities and associated documents such as letters and meeting notes for each company in a custom database that allows us to generate reports for engagement management and evaluation purposes. We track the progress of engagements, taking into consideration three factors: progress towards the achievement of each engagement objective associated with the company, the degree of responsiveness of the company to engagement and the amount of our own effort that has gone into the engagement. We provide quarterly public disclosures on the activity metrics (including deeper dives on selected engagements) and on an annual basis provide disclosure on the progress/success metrics we track.