Responsible Investment Solutions

Conflicts
of interest
Addendum to our Responsible
Investment Engagement Policy

January 2024

Responsible Investment Solutions

Conflicts of interest
At Columbia Threadneedle Investments we seek to act in the best interestsof our clients in our investment management business. We recognise conflictsof interest may arise in our investment activities and any services we provide.
We seek to identify, and then prevent and/or manage conflicts to serve ourclients’ best interests.

This is an addendum to our Responsible Investment
Engagement Policy, outlining our approach to andimplementation of engagement by our Active Ownership(AO) team undertaking in collaboration with our researchanalysts and portfolio managers. It outlines how we deal
with certain potential conflicts between our interests andthose of our clients, or between the interests of two or
more clients, and across all asset classes between our AO
team, who conduct Responsible Investment focused
engagement activity, and other teams within Columbia
Threadneedle Investment (Research, Portfolio Management)
who are also involved in this activity.

Columbia Threadneedle Investment’s Responsible Investment(RI) engagement program is defined and executed by the Active
Ownership (AO) team with input from reo® clients, as well as frominternal fundamental research analysts and portfolio managers,
being an input into the AO team’s determination of strategic
engagement priorities. Our Responsible Investment Engagement
Policy available on our website provides further detail on
the above.

This addendum does not represent a complete list of all
potential conflicts relevant to this engagement activity;
rather it sits alongside our wider conflicts of interest policies
referenced below under which all potential and actual
conflicts of interest identified are monitored, managed and/or mitigated across the organisation. From time to time we
may need to adjust our approach to dealing with conflicts
from that outlined below to deal with the issues raised by aparticular set of circumstances.

We may engage with an issuer where an Officer, Director orEmployee serves on the board of that issuer. Potential conflictsof interest arise if the issuer’s interests differ from those of
Columbia Threadneedle Investments.

Engaging a client’s issuer
We may engage with an investee issuer where the issuer (ora related party such as a sponsored pension scheme) is
also a client. Potential conflicts of interest arise if theengagement objective or outline engagement expectation is
not in line with the issuer’s preferred practices.
We treat all our clients equally in our engagement activities.
We do not alter our position due to a business relationshipthat an issuer may have with us or any other part of thewider Ameriprise Financial, Inc. group although we may
collaborate with other business areas within Columbia
Threadneedle Investments or the wider Ameriprise Financial,
Inc as part of the effective management of any potential
conflict arising because of such a business relationship.
Unless an institutional client instructs us otherwise, weapply our ESG guidelines1 to all client portfolios in a mannerthat considers our clients’ respective investment objectives
and best interests (including best long-term economic interest).
1

2

Engagement of an issuer involving an Officer, Director or
Employee of Ameriprise Financial, Inc or any of its subsidiaries(“Officer, Director, or Employee”)

We manage this conflict by applying this and other Columbia
Threadneedle Investment policies specifically relating to Officers,Directors, or Employees with relationships with companies. For
example, Columbia Threadneedle Investment’s Global Policy –Outside Activities and Family Relationship requires our employees
to declare and disclose their outside business interests. We also
may determine that it is inappropriate for such employees tohave any involvement the engagement with certain companies inwhich our clients invest.

Engagement to favour one client over another:
Potential conflicts of interest could arise where we engage with
an issuer on a matter with a potential outcome that favours one
client over another; for example, because they are larger in termsof their AuM that we manage or service as part of reo®.
We manage this conflict by treating all clients equally in our Active
Ownership activities. In particular: 	Unless an institutional client instructs us otherwise, we apply
our ESG guidelines to all client portfolios in a manner thatconsiders our clients’ respective investment objectives andbest interests. This could result in our acting on a matter thesame or different way for various clients.

Including: applicable RI investment policies, Engagement Policy, Corporate Governance Guidelines, Environmental and Social Practices Statements

Conflicts of interests 	For the annual reo® client consultation, all clients,independent from their AuM, have one vote on prioritisationof issuers and thematic engagement projects.

Other conflict management tools in Active Ownership– Engagement: ur AO Team: We have a team of ESG experts who workOalongside, but independently from, the fundamental researchand portfolio management teams. The AO team leads
the development of our ESG guidelines and undertakes
engagement activities as well as research and analysis. TheAO team forms part of the broader Responsible Investment
Team which reports into the Global CIO.	Information gained from engagement activity (statistics andnarrative on Objectives, engagement activity, milestones, casestudies, responsiveness rating) is shared equally with clientsin each service category with some clients signing up to alevel of service that includes more granular reporting.

Engagement to favour one Active Ownership Analyst or Portfolio
Manager or Fundamental Research Analyst over another:

 versight: The relevant internal investment committees
O
oversee this policy to ensure Columbia Threadneedle
Investment effectively addresses conflicts of interests forengagement. It is committed to safeguarding the integrity of
our AO team. Our Compliance department, as well as, whereapplicable, our investment fund boards, may also periodicallyreview our compliance with this policy.

Potential conflicts of interest could arise within or between teamsof AO analysts, portfolio managers or Fundamental Researchanalysts, if one of their representatives conducts an engagement
alone with an issuer. This could lead to an imbalance of accessto issuer meetings and the sharing of information, andcompromised client reporting. Different asset classes anddifferent strategies may also need to follow different engagement
objectives and engagement prioritisation (e.g. financial, ESG
impact, engagement escalation).
We manage this potential conflict by having a global sharedcalendar, with all teams having information about upcoming
issuer meetings in their calendar, including the option to join. We
also have an annual internal consultation process where portfolio
managers and fundamental research analysts participate in anannual prioritisation process operated by the AO team for priority
issuers, thematic engagement projects as well as fund or
portfolio specific engagement. This process covers bothmanaged asset and reo® clients. In addition, regular exchanges
between fundamental research analysts, portfolio managers andthe AO team take place to understand and align on respective
engagement efforts (scope, Objectives, status etc). The relevantinternal investment committees serve as an escalation point incase prioritisation diverges between any of the parties involved.

 ur compliance and data protection systems: We have strictO
firewalls to keep client holdings data confidential and always
protected, separating holdings of clients with managed
portfolios from those of clients who subscribe only to ourreo® services.
Transparency and disclosure: We seek to uphold highstandards in transparency and disclosure to enable clientsand broader stakeholders to review our effectiveness inmanaging conflicts. Our regular reporting to clients includes
both our public vote record and our annual Stewardship
Code report on Columbia Threadneedle Investment’s Active
Ownership activities with issuers and public policy makers.
 onflicts of interest policy: Columbia Threadneedle
C
Investment maintains wider conflicts of interest policies
under which all potential and actual conflicts of interest
identified are monitored, managed and/or mitigated.

The internal consultation process allows divergent views to beconsidered before our approach is finalised in respect any
engagement initiative but does not occur at the expense of thebest interest of our clients. We treat all clients equally in ourengagement activities.

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