Sustainability Risk Integration and Remuneration Policy –ARTICLES 3 AND 5

This disclosure applies to the group of legal entities whose parent company is TAM UK International Holdings Limited
which is part of Columbia Threadneedle Investments, the asset management business of Ameriprise Financial, Inc.

ARTICLE 3
Sustainability Risk Integration
Columbia Threadneedle Investments EMEA considers sustainability risk when assessing the suitability ofsecurities for investment, and such risks are monitored on an ongoing basis. Sustainability risk is defined
as being an environmental, social or governance event or condition that, if it occurs, could cause a material
negative impact on the value of an investment. The following disclosures describe how Columbia Threadneedle’s
responsible investment policies are applied to mitigate such risks across the various asset classes.

Sustainability Risk Integration: Equity and Fixed Income
We consider a range of sustainability related risks in the investment decision-making process,to the extent that it is possible to do so, by incorporating an issuer’s responsible investment practices andrisks in the research available for the product’s portfolio management team. This research is systematicallyincorporated into our ratings and tools, for use by the portfolio management team when considering
the product’s investment objective, risk within the portfolio, and the implications for ongoing monitoringof holdings.
Responsible investment factors considered by our research analysts and personnel include
assessment of exposure to - as well as management of - environmental, social and governance (“ESG”)
risks including those relating to climate change, and instances of involvement in operational controversies.
For example, when evaluating an issuer’s overall exposure to climate risk, research personnel may consider
the implications of an issuer’s transition away from carbon-intensive activities and its ability to adapt
accordingly, as well as the issuer’s potential exposure to the physical risks of climate change, arising fromits operations, supply chain or market risks. Issuer-level analysis focuses on material, industry relevant
ESG factors, offering us insight into the quality of a business, as well as its leadership, focus and operating
standards assessed through an ESG lens. We incorporate this and other external research into ESG
ratings and reports via tools it has developed for that purpose and utilizes such information when making
investment decisions for the product.
Further, as applicable, our research considers any flags around issuers’ operations in accordance withinternational standards such as the UN Global Compact, the International Labour Organisation corelabour standards and the UN Guiding Principles for Business and Human Rights. These factors may
provide insight into the effectiveness of the risk management oversight of an issuer’s sustainability
practices and external impacts.
We may also seek to manage sustainability risks and impacts of an issuer through its stewardship efforts,
and where appropriate, through its exercise of proxy voting rights. In accordance with applicable law, theproduct’s portfolio management and responsible investment analysts may determine to engage an issuer
in dialogue regarding its sustainability risk management practices.

Sustainability Risk Integration: Real Estate
We consider sustainability risk factors when assessing responsible investment performance across eachof the five core areas of the real estate business. A key focus within this is to understand and mitigate
the potential physical and transitional risks of climate change given the related significance within theasset class.

Sustainability Risk Integration and Remuneration Policy –ARTICLES 3 AND 5

Property Investment – When assessing any new property investment, our standard due diligence protocol
requires all buildings to be comprehensively surveyed from a structural, mechanical and environmental
perspective prior to purchase. Consideration is given to a wide range of factors including energy
performance (e.g. via Energy or Sustainability audits), minimum energy standards, environmental risks(including flood risk), climate impact, and areas for potential improvement in terms of sustainability
performance.
Asset Management – We encourage both occupier engagement and community engagement opportunities
where appropriate. Data sharing and co-operation clauses are introduced into leases where possible, toenable the monitoring of operational energy, water and waste consumption. Consideration is given to thecost and timing of undertaking any physical improvements to buildings at lease events.
Property Management – We support external managing agents in delivering against annual key
performance indicators e.g. with respect to carbon emissions reductions, energy and water usage
improvement, prevention of pollution and minimisation of waste.
Health and Safety, Risk and Governance – We ensure that Health and Safety risks for all properties arecorrectly identified and managed. In order to meet the products’ responsibilities and protect the wider
community, we ensure all necessary inspections are conducted regularly and ensure oversight throughmonthly reporting, meetings with the agents and independent annual audits.
In addition, to identify and monitor climate change risks we work with insurers to obtain enhanced flood
data on every asset and obtaining a flood risk rating, which is reviewed on an annual basis.
Refurbishment – A Refurbishment Guide is provided to project managers and will be provided tocontractors, as part of a project brief, for use in minimising adverse environmental and social impacts
on site and to maximise the creation of economic opportunities in the local community, as applicable.
All construction projects incorporate a set of minimum requirements as defined in the Refurbishment
Guide, relating to environmental management, building quality and flexibility, health and well-being, energy
efficiency, transport, water, building materials, waste management, ecology and pollution.

Sustainability Risk Integration: Commodities
We integrate sustainability risk into the investment decision-making process, seeking to manage or avoid
the types of risk that can arise within the asset class. The integrated approach is comprised of thefollowing elements:
Type of exposure – Investments are made in commodity derivatives as this enables us to gain exposure
to the asset class while mitigating the sustainability risks associated with direct, physical or real assetexposures.
Exclusions – We recognise that some classes of commodities are more exposed to sustainability issues
than others and do not invest in those where particularly sensitive issues commonly arise, such as coal,
tobacco, palm oil and diamonds.
Choice of benchmark – We use benchmarks which are evenly diversified across sectors and avoid
excessive exposure to fossil fuels.
Liquidity – The liquid nature of the chosen benchmark also assists us in managing risks associated withinvestments being made in smaller, more illiquid commodity markets, which could give rise to distortions
or impacts on pricing.

Sustainability Risk Integration and Remuneration Policy –ARTICLES 3 AND 5

Positive inclusion – Investment in off-benchmark commodities is subject to a positive inclusion review forsustainability risk and must be positively approved prior to inclusion within the strategy.
Thematic research and reviews – Research capabilities and insights across macro, fundamental, thematicand responsible investment factors are leveraged to inform the strategy and investment process.
Counterparty screening – All approved counterparties are subject to a sustainability risk review where theyare screened against responsible investment factors including internationally accepted standards suchas the UN Global Compact, International Labour Organisation core labour standards and the UN Guiding
Principles on Business and Human Rights.

Sustainability Risk Integration: Multi-Asset
Within the Funds that comprise our managed and multi asset fund ranges, there are a number of types ofunderlying investments including but not limited to funds managed by Columbia Threadneedle Investments
EMEA and our affiliates, passive strategies managed by third parties, and direct holdings. Individual Funds
invest in a variety of these dependent on what the mandate is designed to achieve. For all such Funds,
consideration of sustainability risk is integrated into selection of the underlying investments, be they director through other funds, and at the overall Fund level.
Where Funds invest in other funds managed by our affiliates, the process for managing sustainability
risk at the Fund level is as described above (see Sustainability Risk Integration for each of the underlying
asset class).
Where Funds gain exposure to securities directly, rather than through other funds, integration ofsustainability risk is considered in security selection in the same way as described above for equity andfixed income funds. The Funds do not invest directly in commodities or property.
For our Managed Fund range, the aggregate sustainability risk exposure across the underlying funds ismeasured and collated at the Fund level and then compared against the Managed Funds strategic asset
allocation benchmark for comparison purposes.
For the multi asset fund range, the aggregate sustainability risk exposure across the underlying funds ismeasured and collated at the Fund level and then compared against the multi asset funds actual asset
allocation at the end of the month for comparison purposes. To explain this, if a multi asset fund at theend of the month has invested in three different internal funds (UK equities, US equities and UK CorporateBonds) in equal proportions then the comparison will be the collated internal fund sustainability risk v theunderlying funds benchmark (so in this case FTSE All-Share Index, S&P 500 Index and iBoxx Sterling NonGilts) for comparison purposes.

Oversight of Risk Management
The management of sustainability related risks in products across appropriate asset classes isindependently overseen by a dedicated risk management team, whose role includes monitoringsustainability risk measures relative to the product’s objectives and risk appetites. The sustainability
risk measures monitored include many of the factors described above, although estimated and judged
independently of the research process. Sustainability risk management can, if needed, include theescalation of concerns though independent channels, providing a strong governance frameworkaround risk taking.

Sustainability Risk Integration and Remuneration Policy –ARTICLES 3 AND 5

ARTICLE 5
Remuneration policy
Columbia Threadneedle Investments EMEA has, effective from 10th March 2021, incorporated theassessment of sustainability risk into its performance goals for relevant businesses managing productsthat integrate sustainability risk. Leaders will be expected to consider sustainability risk alongside otherinvestment risk types when assigning a performance appraisal rating. This rating is a factor in making
remuneration decisions for each employee in accordance with the structure and design of the Firm’s
remuneration programmes. Where sustainability requirements form part of a product mandate, a breach ofthese requirements may trigger a risk event investigation which could result in adjustment of remuneration.
Columbia Threadneedle Investments EMEA’s remuneration policy has been updated to reflect
these changes.

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Important Information. Information is provided in reference to Sustainable Finance Disclosure Regulation (Regulation (EU) 2019/2088 and may be subject to change, following new or updated Regulatory
guidance or other changes. Please refer to the current fund prospectus or Investment management agreement for further details and all risks applicable to investing. The information provided in thisdocument may not be reproduced in any form or passed on to any third party without the express written permission of Columbia Threadneedle Investments. This document is the property of Columbia
Threadneedle Investments and must be returned upon request.
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