RESPONSIBLE
INVESTING
PRACTICES

Contents
Introduction

1

Our purpose

1

Governance structure of our integrated approach2

Responsible investing beliefs and policy

3

Climate-aware investing4

Responsible investing in practice6

Manager due diligence

6

Portfolio management

7

Insights and research

7

Active ownership

8

Culture and process

11

Transparency

12

Performance and fund reporting

12

Voluntary reporting

12

Qualitative manager reports

12

Quantitative metrics

12

Russell Investments / Responsible Investing Practices

Introduction
As a global investment solutions provider, Russell Investments is committed to integrating responsible investing practices
that align with our core values and enable us to deliver attractive investment returns that meet client objectives. As aninvestment firm, we recognize our pivotal role in driving meaningful change through our investment decisions and active
engagement with companies. We believe that generating sustainable financial returns can go hand in hand with making a
positive impact on the world around us. We believe our deep understanding of asset managers, built on decades of researchand use of proprietary in-house tools to monitor portfolio positions, gives us a competitive advantage in the market.
Responsible investing is a strategy and practice which incorporates consideration of environmental, social and governance(ESG) elements into investment decisions and active ownership. It complements traditional financial analysis and portfolio
construction techniques. Russell Investments’ policy is to incorporate responsible investing into our investment manager
evaluation process, our portfolio management, our advisory services, and when implementing proprietary solutions as
desired by clients.
In this paper, we outline our responsible investing beliefs and practices. However, as a global solutions provider, weunderstand that a one-size-fits-all approach does not work for many. Our clients have a wide range of priorities when it comesto investing responsibly. At Russell Investments, we offer bespoke solutions that allow clients to meet their individual
requirements using desired approaches to integrating ESG considerations.

Our purpose
Russell Investments focuses on meeting our clients' needs through outcome-oriented solutions that incorporate efficient risk
management techniques. This focus is built upon a complementary mix of our market-leading capabilities in manager
research, portfolio implementation, asset allocation, portfolio construction, and total solutions management.
Our company’s foundation lies in the people and values of Russell Investments, which have contributed to our long-term
success. Our corporate values are rooted in the following principles:1.

We behave with non-negotiable integrity.

2.

We value our people and are dedicated to fostering a meritocracy. Our pillars are inclusivity, humanity, fairness, hard
work, creativity, teamwork, fun and humility.

3.

We play to win by exceeding client expectations and executing with a sense of urgency and purpose.

4.

We are passionate investors who embrace intellectual curiosity and rigor.

Founded in 1936 and today headquartered in Seattle with operations in the EMEA, North America and Asia-Pacific regions,
Russell Investments is a global investment firm that provides investment management, advisory and implementation(execution) services. Our global assets under management (AUM) exceed $297.9bn, supported by over 1,300 associates wholeverage their combined expertise to deliver client outcomes1. We prioritize building strong partnerships with our clients to
help them achieve their objectives.
Since 1980, our primary business has been serving institutional and retail clients around the world, predominantly throughoutsourced solutions. At Russell Investments, we stand with you, whether you’re an institutional investor, a financial adviser,or an individual guided by an adviser’s personalized advice. We cater to clients of all sizes, ranging from smallerorganizations to large governmental entities seeking customized solutions. Our business plans emphasize continued focus,
investment growth, and innovation in the responsible investing space.

1

As of 30 June 2023

Russell Investments / Responsible Investing Practices/1Governance structure of our integrated
approach
Our organization’s policies and practices are supported and developed by formal groups that play a crucial role in evaluation anddecision-making. These formal groups bring together experts from various investment disciplines to drive our manager research,
portfolio management, active ownership, and operational due diligence programs.
Our Responsible Investing teams and initiatives are overseen by our Global CIO, Kate El-Hillow, demonstrating Russell
Investments’ commitment from the top. Our executive sponsor oversees two ESG councils, namely the Go-to-Market
Responsible Investing Council (GTMRIC) and the Investment Division Responsible Investing Council (IDRIC).
The GTMRIC is responsible for guiding our investment deliverables and Go-To-Market (GTM) activities related to responsible
investing. Its primary focus is to ensure we deliver the best possible responsible investing solutions and outcomes to our clients
globally. The council comprises representatives from across the business including the investment division as well as product,
marketing, legal and client-facing teams.
Another vital group is the IDRIC, which operates under the authority of the Investment Strategy Committee, the highest investment
governing body at Russell Investments. This council guides the Investment Division’s initiatives concerning responsible investing
and consists of subject matter experts and key leaders from our Research and Portfolio Management teams. The council’s mission isto advance excellence, collaboration, and consistency in Russell Investments’ responsible investing practice.
The Responsible Investing Councils are chaired by dedicated ESG professionals who also oversee specific practice areas including
ESG solutions, strategy, investment process, and quantitative research and analysis. In addition to these two groups, we havemultiple responsible investing-related working groups, assigned with specific tasks such as research delivery (including climaterelated), strategy evolution, compliance with the fast-changing regulatory landscape, and client-facing training and development.

GTM Responsible Investing Council (GTMRIC)
Operating Committee Sponsor
Chair: Head of Global ESG Strategy

SolutionsSales
strategy

GTMstrategyMarketing

Legal andcompliance

Investment
Division

ID Responsible Investing Council (IDRIC)
Operating Committee Sponsor
Chair: Head of ESG Investment Management

Activeownership

ESG research

Privatemarkets

Russell Investments / Responsible Investing Practices

Portfolio
management

Manager
research/2

Responsible investing beliefs
and policy

Responsible Investing Policy
Russell Investments’ policy is to integrate responsible investing throughout our investment manager evaluation
process, portfolio management, advisory services, and when implementing proprietary solutions as desired by clients.
Responsible investment entails considering environmental, social and governance (ESG) issues when making
investment decisions and leveraging active ownership to more effectively manage risk and generate sustainable, longterm returns. Our approach in all cases is guided by our fiduciary duty.

As a global investment solutions provider, we firmly believe that the inclusion of ESG factors can provide investors withvaluable insights into the long-term sustainability and profitability of companies. We recognize that responsible investing can
not only help deliver attractive investment returns but also align with our clients’ objectives.
Our professionals possess a deep understanding of how sustainability issues impact the financial performance of various
investments across asset classes, and their aim is to identify and act on material financial risks and opportunities. We believethat companies with robust ESG practices are more likely to mitigate environmental risks, enhance their brand reputation,
attract top talent, and maintain stronger stakeholder relationships, all of which contribute to their long-term financial
resilience.
At our firm, we view sustainable investing as intelligent investing, and we have built our responsible investing practice on aset of four core beliefs.

Russell Investments / Responsible Investing Practices/3

Climate-aware investing
Climate change-related risks have emerged as one of the most significant ESG concerns in the global investment industry. Theserisks encompass potential damage to property and infrastructure resulting from extreme weather events, policy shifts impacting
market preferences, legal actions against climate change-contributing companies, and the potential devaluation of industries withhigh emissions. Such risks can lead to financial losses, increased costs, and decreased profitability for companies and investors who
are not prepared for the shift to a more sustainable, low-carbon economy.
At Russell Investments, we are committed to thoroughly researching, measuring, reporting, and considering climate change risks
and opportunities as integral parts of our investment practice. We bolster that commitment through our active ownership, wherever
relevant, while continually striving for best practices across our business operations.
Our attention to this issue rests on specific climate change beliefs:

Future climate events and shocks will affect future security prices

Current security prices may not reflect current climate change risks and opportunities

The ability to recognize systematic or idiosyncratic mispricing presents skillful asset managers an
opportunity to add investment value through both risk management and opportunity capture

Active ownership may be used to migrate climate-change related risks, or to help foster effective
adaptation for individual securities and markets.

In the years since the launch of our first low carbon funds in 2015, our approach to climate-aware investing has evolved and adaptedwith market conditions and client expectations. In 2021 Russell Investments made a firm-wide net zero commitment with thefollowing action points:
Work in partnership with interested clients to establish clear decarbonization goals, consistent with an ambition to reach net
zero emissions by 2050 across all assets under management (AUM).



Set an interim target for the proportion of assets to be managed in line with the attainment of net zero emissions by 2050 orsooner.



Review our interim target at least every five years, with a view to ratcheting up the proportion of AUM covered.

To support our innovation and supplement our existing climate metrics, we established an ongoing partnership with a specialist
climate risk provider. This collaboration arose from a comprehensive review of emerging climate risk vendors, and in 2022, wepublished our inaugural TCFD report, found here2. Our efforts are ongoing. In 2023, we launched an internal net zero dashboard
tool to aid portfolio managers and product teams in monitoring and managing funds with net zero objectives, and we have begun
work to incorporate climate change modelling into our capital markets assumptions, underscoring our dedication to staying at theforefront of climate-related considerations.

2

TCFD Report (2022). Russell Investments. Available here: https://russellinvestments.com/-/media/files/_request/US/Corp/TCFD_Report.pdf

Russell Investments / Responsible Investing Practices/4

Of course, our solutions and progress toward these goals is always client-led. While a decade ago a climate-aware portfolio
may have revolved around divesting from fossil fuels, our solutions today are more nuanced and adaptable to client needs. In
addition to systematic low carbon products, these solutions can include active manager strategies that offer:Reduced carbon intensity of the portfolio (emissions per unit of revenue)High carbon intensity but with increased investments in green technology or better alignment to the EU taxonomy

High exposure to energy companies, but with focus on engaging with companies to set science-based targets. Thisapproach has the advantage of promoting real world progress by engaging with high impact companies

Climate Change Policy
Russell Investments' policy is to research, measure, report, and consider climate change risks and opportunities as
integral parts of our investing practice, and we bolster that commitment through our active ownership, whereapplicable. Our measures, reported metrics, and consideration of climate risk and opportunities are all integrated into
our research and selection of external investment managers, portfolio management, advice, proxy voting, shareholder
engagement and day-to-day business.

Russell Investments / Responsible Investing Practices/5Responsible investing in practice
We strive to employ a firmwide, holistic, ESG-integrated approach to our investment process. Responsible investing isembedded in our manager research as well as portfolio construction processes as detailed below. In each step, we identify
and manage sustainability risks.

Sustainability Risks Policy
Russell Investments’ policy is to integrate sustainability risk3 management into our investment solutions by identifying,evaluating and managing relevant risks in our investment manager review process, portfolio management and throughimplementing proprietary solutions. We believe sustainability risks are most relevant to investment outcomes when
they exhibit financial materiality, and, like all investment risks, are incorporated by balancing expected risk withexpected reward. In managing investment solutions, we consider financially-material sustainability risks in thecontext of expected rewards using a blend of inputs from sources including, but not limited to, investment managers,
third-party data sources, and Russell Investments propriety analysis. Furthermore, we incorporate bespokesustainability risk management and explicit controls based on clients’ requirements for customized mandates. As well,
we seek to collaborate with our advisory clients to consider, monitor and manage sustainability risk priorities in theirportfolios.
.

Manager due diligence
We believe ESG considerations should sit alongside traditional assessments as a part of the overall investment consideration
for strategy evaluation. As a natural evolution of our manager research process, manager research analysts have assigned an
ESG rank to individual strategies since 2014.
The ESG ranks range from one to five, with a ranking of three considered consistent with a peer group average. The ESG rank
includes the following sub-scores:

ESG Commitment



ESG Considerations

ESG Implementation



Active Ownership

ESG rankings are determined through a comprehensive analysis that combines both qualitative and quantitative assessments.
The rankings are informed by three key components:


Dedicated ESG and due diligence: During in-depth manager due diligence meetings, we evaluate the extent to which
key investment decision-makers are aware of potential ESG risks and returns. We also assess how these ESG insights aretranslated into the portfolio positioning.

Data and analytics: We utilize quantitative data to analyze portfolios through an ESG lens. Our proprietary systems -PARIS, ExploreR, and ENACT -- provide ESG data and insights at both the portfolio and holdings levels. This includes
risk data from Sustainalytics and carbon footprint metrics from MSCI. These valuable inputs inform our manager
research discussions.



ESG manager survey: We conduct an annual ESG Manager Survey to obtain firm-level information about ESG-relatedresource availability and to provide supplemental information on how asset managers are incorporating ESG
considerations into their investment processes.

By leveraging this combination of inputs, our research analysts generate a robust and comprehensive picture of whether amanager appropriately assesses and manages the risk and return impacts of ESG issues.

3

Russell Investments defines “Sustainability Risks” as financially-material risks related to environmental, social, or governance (ESG) issues that are relevant to ourinvestment practice.

Russell Investments / Responsible Investing Practices/6Russell Investments’ manager research analysts have reviewed hundreds of products specifically targeting ESG or sustainableobjectives alongside their performance goals. We classify these products as having "ESG Intent" and subject them to special
scrutiny in a process called "IPO," which stands for Intent, Process, and Outcome. Consistent with our traditional investment
universes, less than 10% of these strategies have earned a positive formal rank from our research analysts. Our portfolio
managers and clients can utilize these recommendations and research when constructing multi-manager solutions with
explicit ESG or sustainable goals. This ensures that our investment decisions are well-informed and aligned with our clients'
specific ESG preferences and objectives.

Portfolio management
When constructing our multi-manager portfolios, we include actively managed investment products that have achieved thehighest overall ranks. Russell Investments’ portfolio managers choose active managers from among those ranked highly by
our manager research teams, utilizing our ESG ranks alongside metrics on ESG and carbon footprint, as well as traditional
profile and exposure data.
For clients with specific ESG-related objectives, we have developed and delivered products centered around sustainability
themes. All manager appointments are carefully considered and approved by the various governance groups within theInvestment Division. This ensures that the selection of managers aligns with our commitment to delivering optimal
investment outcomes for our clients.

Sustainability risk management
Under our Sustainability Risks Policy, portfolio managers identify and assess financially-material sustainability risks within
portfolios on an ongoing basis. They do this by using available metrics, Russell Investments’ proprietary analysis, anddialogue with external investment managers. If a potential sustainability risk is identified, one or more of the following
actions may be taken in an investment process we call “Enhanced Oversight”:
Review of the drivers or sub-components of any metrics behind the highlighted risk



Thesis review with the external investment manager supporting the holdingDiscussion with Russell Investment’s Active Ownership team to consider engagement options

Our Sustainability Risks Policy pertains to all investment solutions where Russell Investments has discretionary managementof invested assets. It also extends to bespoke solutions and advice for customized mandates, where directed by clients.
However, this policy does not typically apply to custom implementation services where Russell Investments is acting as anagent on a client’s behalf such as transition management, overlay services, currency management, and outsourced securitiestrading services.
Our beliefs drive our policies and investment practices and, ultimately, reflect how we act as responsible stewards of assets tocreate long-term value for our clients and beneficiaries.

Insights and research
We continually evolve our research efforts to deepen our understanding of sustainability risks. This commitment is evident inour strategy development, metrics, and reporting, as well as industry analysis.

Strategy development
Our researchers are dedicated to developing and refining ESG-related strategies, including Decarbonization 2.0, impact
investing, and ESG-themed solutions. For our products with a carbon-related focus, we incorporate proprietary carbon andother ESG-related metrics. As part of our efforts, we have created a proprietary Green Energy Ratio, which measures thepercentage of energy generated by a utility from renewable sources (green energy). This metric helps identify potential
climate transition champions through climate change mitigation technologies.

Metrics and reporting
Our internal reporting and oversight include multiple industry-standard metrics, along with our own proprietary metrics suchas the Material ESG Score. Additional proprietary metrics are developed as more robust data and methodologies are
identified.
Where data is available and robust, Russell Investments professionals monitor portfolio holdings using a range of measures.
In 2023, we rolled out significant ESG data enhancements to our portfolio attribution and reporting tool. The aim is toquantitatively identify securities that have a higher probability of having high and material sustainability risks. Measuresconsidered may include, but are not limited to, the following:

Russell Investments / Responsible Investing Practices/7

Sustainalytics Risk Rating

Carbon metrics including emissions and weighted average carbon intensity



Russell Investments Material ESG Score - combines Sustainalytics Risk Ratings with the Sustainability AccountingStandards Board (SASB) materiality map to identify financially material ESG-related issues in each security

Sustainalytics’ Controversy Score

UNGC Compliance

Data sources and availability vary by asset class and product type, resulting in potential differences in data utilization
practices among asset-class teams.

Active ownership
Proxy voting
Russell Investments has a robust proxy voting and governance process, geared toward engagement on issues related tofinancially- material ESG factors. A key element of our process involves the active participation of a broad set of experienced
investment professionals at Russell Investments. This ensures thorough evaluation of investment risks and rewards in our
active ownership endeavors, including proxy voting on ESG-related matters.
We have a dedicated active ownership team, as detailed in our comprehensive active ownership structure below. More detailon our proxy voting and engagement efforts can be found in our Investment Stewardship Report4 and our Responsible
Investing home page.

*Responsibilities:
Chair: Oversight of all processes and procedures of the committee and its stewardship actions. Chair may function as a tie-breaking vote.
Voting members: Comprised of senior investment professionals charged with voting on policy/procedural changes and proxy proposals.
Legal representative: Oversees all developments and actions of the committee and its stewardship actions.

The Active Ownership Committee establishes and oversees our proxy voting policies, procedures, guidelines and voting
decisions, while continuing to adapt our processes to meet evolving client needs and expectations. The Committee is madeup of experienced Russell Investments professionals from a variety of investment roles, including portfolio management,
manager research and investment strategy. Glass Lewis serves as our proxy administrator and is responsible for applying ourcustom guidelines when executing proxy votes.

Engagement
Our objective, through our active ownership activities, is to deliver an integrated and inclusive approach to promote changes
aimed at protecting and enhancing shareholder value and shareholder rights.
As a premier investment-solutions partner with extensive multi-asset and multi-manager capabilities, we leverage a wide range ofrelationships to exert influence and facilitate multiple levels of engagement. These connections extend across external investment
4

Investment Stewardship Report (2022). Russell Investments. Available here: https://russellinvestments.com/-/media/files/us/corporate/investment-stewardship-report.pdf

Russell Investments / Responsible Investing Practices/8managers, standard setters, proxy and engagement service providers, other market participants and, of course, corporate issuers.
These relationships not only enable us to share information but also serve as a valuable feedback loop, enriching our active
ownership process.
We categorize our activities in three ways: Russell Investments-led direct corporate engagement; dialogue with and through our
external investment managers; and our collaborative engagements, including those led by our engagement service provider,
Sustainalytics.
Russell Investments sets our engagement priorities at the firm and fund level, taking into account our overall ownership stake andfirmwide aims in addition to bottom-up portfolio exposures. Internally led, direct company engagements are frequently initiated on
the back of proxy items. Many relate to votes that have been referred to the Active Ownership Committee for analysis, debate, and amanual vote.
Any referred item that is voted on by the Committee is a potential engagement opportunity. However, Russell Investments will apply
additional criteria when selecting targets for engagement, including some, or all, of the following:

Russell Investments’ ownership stake, as percent of shares outstanding and/or weight of fund exposureProxy voting history and management responsiveness to shareholder concerns

ESG analysis performed in-house and by third-party vendors of ESG metrics focusing on sub-industry peer comparison and
ESG-related controversies



Research and analysis from Glass Lewis, our proxy voting administrator

Any history of previous engagement activity

Opportunities highlighted by our sub-advisers

Engagement targets are finalized using the input and insights of our portfolio management teams, often gathered through ourEnhanced Oversight process, and approved by Russell Investments’ Investment Strategy Committee.
In 2022, Russell Investments released an internal platform called ENACT which was built to improve the sharing of ESG-related
insights. The name ENACT was drawn from the combination of two of our critical responsible investing practices: Enhanced
Oversight and Active Ownership. ENACT is a proprietary tool for capturing sustainability risk management efforts and formonitoring progress toward explicit engagement objectives. The platform enhances visibility and communication across the firm
and at the fund level.
We understand that many issues are worthy of engagement, so we apply the criteria listed above to highlight the opportunities
which offer the highest risk, return, and change opportunities for our portfolios and on behalf of our clients and stakeholders.
While ESG considerations encompass a wide range of worthwhile shareholder concerns, Russell Investments has prioritizedengagement efforts under the following six focus areas:

ENVIRONMENTSOCIAL

GOVERNANCE

Natural Capital

Human Capital

Board Composition &Accountability

Focus

Focus

Focus

Encourage responsible
environmental management andsustainable usage of resources

Improve how companies attract,develop, and retain employees whileproviding appropriate working
conditions

Action on the board of directors
which is the focal point ofcorporate governance

Climate Change Resilience

Diversity & Inclusion

Executive Compensation

Focus

Focus

Focus

Promote increased transparency
on climate related disclosuresand practices

Raise awareness of the impact ofdiversity on firm’s investment
performance and culture

Align executive compensation
with corporate performance

Russell Investments / Responsible Investing Practices/9Russell Investments has leveraged a partnership with Sustainalytics for collaborative engagements since 2020. Sustainalytics’
thematic engagement programs are designed to extend over a three-year period, allowing Russell Investments and otherparticipants to build relationships with a set of issuers and to encourage action that promotes long-term value.
In alignment with our five focus areas, Russell Investments is currently supporting programs of thematic engagement including:

1. Japan material risk
2. Natural capital and biodiversity
3. Sustainable forests and finance
4. Human capital and the future of work
5.

Modern slavery

We are also proud to be members of the Climate Action 100+, a joint investor initiative to ensure the world’s largest greenhouse gas
emitters take action on climate change. As members of the Climate Action 100+ initiative since early 2020, and in line with our Net
Zero commitment, Russell Investments has engaged directly with a select number of companies on climate transition.
To find out more about our engagement efforts view our Engagement Policy5.

Collaborative initiatives
Below, we provide a list of the trade organizations and industry initiatives that we are affiliated with.

Principles for Responsible
Investment (PRI)

Institutional Investors Groupon Climate Change (IIGCC)

Climate Action 100+

Transition Pathway
Initiative (TPI)

Carbon Disclosure
Project (CDP)

Task Force on Climate-related
Financial Disclosures (TCFD)

The Net Zero AssetManagers initiative

Investment Company
Institute (ICI)

5

Institutional Investing Diversity
Cooperative (IIDC)

Securities Industry
and Financial
Markets Association(SIFMA)

Responsible Investment
Association Australasia(RIAA)

Investment
Association (IA)Department ofLabor (DOL)

Engagement Policy (2023). Russell Investments. Available here: https://russellinvestments.com/-/media/files/us/corporate/engagement-policy.pdf

Russell Investments / Responsible Investing Practices/ 10

Culture and process

Russell Investments’ culture is built on a commitment to a foundational set of beliefs and practices. These provide a richcombination of real-world guidance and an overarching ethic within which we conduct our business. These are captured in
the following four pillars:
1.

Corporate values: Russell Investments' people and values are the foundation of our company and the reason for our
long-term success.

2.

Sustainable work practices: Our mission is to identify and reduce our impact on the environment by ensuring that ourday-to-day procedures are carried out in the most sustainable manner.

3.

Diversity, equity, and inclusion: We believe that diversity, equity, and inclusion in the workplace drives better
performance. Diversity is integral to our long-term growth.

4.

Community involvement: We are committed to supporting the communities in which we live and work. We also have an
extensive internal program that promotes diversity and inclusion, corporate giving, volunteering, and sustainable work
practices. Full details can be found here6.

Below are some of the organizations we are proud to collaborate with:

6

Corporate Social Responsibility (2022). Russell Investments. Available here: https://russellinvestments.com/-/media/files/us/corporate/corporate-social-responsibilityreport.pdf

Russell Investments / Responsible Investing Practices/ 11

Transparency
Performance and fund reporting
We provide monthly reporting on investment performance and all related fund information for all listed assets and quarterly
reporting for all unlisted assets. In cases where clients or regulatory bodies require reporting on ESG scores, carbon metrics,
or impact investing information, we ensure that the frequency of reporting aligns with our investment reporting cycles. In
response to client demands, we have developed dedicated ESG fund reporting profiles to cater to specific needs in this area.

Voluntary reporting

United Nations-supported Principles for Responsible Investing (PRI) - Russell Investments recognizes the importance ofenvironmental, social, and corporate governance issues and is committed to continual capacity enhancement, inpartnership with our clients and other industry organizations. We submit a comprehensive annual report to the PRI.

The Task Force on Climate-related Financial Disclosures (TCFD) is an organization that was established in December
2015 with the goal of developing a set of voluntary climate-related financial risk disclosures. Our TCFD report is available
here.



Russell Investments produces an annual Investment Stewardship Report7, which satisfies submission requirements for
the UK Stewardship Code, the New Zealand Stewardship Code, as well as the Japan Principles for Responsible
Institutional Investors. This report contains detailed information on our active ownership program, and we provide
custom active ownership reporting to our clients, as requested.

Russell Investments publishes our proxy voting record, searchable by fund and company, on an annual basis, which isavailable to the public through our Responsible Investing site.
Internally, we report all active ownership activity on a quarterly basis to our Active Ownership Committee. Engagements arerecorded and tracked in our proprietary tool, ENACT.
Since 2020, to ensure that our activities are aligned with best practice principles, the Active Ownership Committee has
conducted an enhanced internal audit process, to ensure our proxy provider accurately casts proxy votes in accordance with
our guidelines.

Qualitative manager reports
On a regular basis, we monitor and report the ESG ranks we assign to investment managers. These ESG ranks sit within thecontext of our full analyst assessment, which are used in portfolio construction, ongoing oversight and management.

Quantitative metrics
We produce a variety of sustainability-related metrics for our portfolios, funded and researched managers, and benchmarks
for both equity and fixed income asset classes. These metrics are available for internal analysis and may be made available
for external reporting, as required. x

7Investment Stewardship Report (2022). Russell Investments. Available here: https://russellinvestments.com/-/media/files/us/corporate/investment-stewardship-report.pdf

Russell Investments / Responsible Investing Practices/ 12

QUESTIONS?
Call Russell Investments at 855-771-2966
or visit russellinvestments.com/InvestResponsibly

ABOUT RUSSELL INVESTMENTS
Russell Investments is a leading global investment solutions partner providing a wide range ofinvestment capabilities to institutional investors, financial intermediaries, and individual investors
around the world. Since 1936, Russell Investments has been building a legacy of continuous
innovation to deliver exceptional value to clients, working every day to improve people’s financial
security. Headquartered in Seattle, Washington, Russell Investments has offices worldwide,
including New York, London, Sydney, Tokyo, Toronto and Shanghai.

IMPORTANT INFORMATION
Nothing contained in this material is intended to constitute legal,tax, securities, or investment advice, nor an opinion regarding
the appropriateness of any investment, nor a solicitation of any
type. The general information contained in this publication
should not be acted upon without obtaining specific legal, tax,
and investment advice from a licensed professional.
Russell Investments' ownership is composed of a majority stake
held by funds managed by TA Associates Management, L.P.,
with a significant minority stake held by funds managed by
Reverence Capital Partners, L.P. Certain of Russell Investments'
employees and Hamilton Lane Advisors, LLC also hold minority,
non-controlling, ownership stakes.
Frank Russell Company is the owner of the Russell trademarks
contained in this material and all trademark rights related to theRussell trademarks, which the members of the Russell

Investments group of companies are permitted to use underlicense from Frank Russell Company. The members of theRussell Investments group of companies are not affiliated in any
manner with Frank Russell Company or any entity operating
under the “FTSE RUSSELL” brand.
Copyright © 2023. Russell Investments Group, LLC. All rights
reserved. This material is proprietary and may not be
reproduced, transferred, or distributed in any form without priorwritten permission from Russell Investments. It is delivered onan "as is" basis without warranty.
First used: October 2023
AI-29914-10-26