Controversial Weapons Policy
Columbia Threadneedle Investments
June 2024

Background
At Columbia Threadneedle Investments we recognise the value in effectively integrating environmental, social andgovernance factors into our investment processes. Our conviction in this approach was evidenced in Europe bysigning up to the Principles for Responsible Investment in 2006, which has since been applied globally. In applying
these Principles, we identified the need to enhance our ownership policies to improve stakeholder protections. Ouroriginal controversial weapons policy was shaped by legal prohibitions on depleted uranium and cluster munitions
enacted in the late 2000s. Over time, the 2011 policy has been updated to respect legal requirements across a
broader range of weapons and jurisdictions, governing all active strategies managed by subsidiaries of TAMUK,
part of Columbia Threadneedle Investments, EMEA.

PolicyTo protect our clients and broader stakeholders’ interests, we have maintained a controversial weapons exclusion
policy since 2011. Reflecting both international conventions and the legal requirements in certain jurisdictions,
we seek to avoid our active strategies investing in companies involved in the production, sale or distributionof controversial weapons including landmines, cluster munitions, blinding laser, non-detectable fragment andbiochemical weapons and depleted uranium ammunition and armour.
Our definition of production extends to manufacturers of controversial weapon systems, munitions, exclusive delivery
platforms and key components. This includes companies that own 50% or more in another firm engaged in suchactivities. Dual use platforms or components and past involvement in these weapons are not included in scope.
If an investment becomes exposed to excluded activities, it should be divested as soon as possible, and no later than
30 calendar days.* Where an issuer is involved in excluded activities, we reserve the right to take short positions insuch securities.

*In exceptional circumstances, the Head of Asset Class may approve an extension to divest in accordance with the applicable regulatory requirements.
This policy applies to the group of legal entities whose parent company is TAM UK International Holdings Limited (TAMUK) which is part of Columbia ThreadneedleInvestments, the asset management business of Ameriprise Financial, Inc.

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Basis
Exclusions under the core controversial weapons policy will be applied in line with the following international
conventions and national law which prohibit the production, sale, distribution and use of the following weapons:
WeaponBasis

Effective

Biological

UN Biological Weapons Convention

1975

Blinding Lasers

UN Convention on Certain Conventional Weapons, Protocol IV

1998

ChemicalUN Chemical Weapons Convention

1997

Cluster Munitions

UN Convention on Cluster Munitions

2010

Depleted Uranium (incl. armour)

Belgian Law on Weapons (Loi sur les Armes)

2009Land MinesUN Anti-Personnel Landmines Convention

1999

Non-Detectable Fragments

UN Convention on Certain Conventional Weapons, Protocol I

1983

Additional exclusions for white phosphorus and nuclear weapons are integrated into our general exclusions
framework for developing fund strategies, for example, those funds which promote environmental and/or social
characteristics or have a sustainable investment objective. These exclusions refer to the following international
conventions:WeaponBasis

Effective

White Phosphorus

UN Convention on Certain Conventional Weapons, Protocol III

1983

NuclearUN Treaty on the Non-Proliferation of Nuclear Weapons

1970

UN Treaty on the Prohibition of Nuclear Weapons2021

It was recognised that white phosphorous may be deemed controversial only in specific applications and its use isregulated without total prohibition. Where we seek to avoid investment in nuclear weapons, we respect the principleof disarmament underpinning the Non-Proliferation Treaty, and more stringent requirements under the Treaty on theProhibition of Nuclear Weapons.

Implementation
In implementing our policy, we engage a third-party research provider to help identify companies involved in theproduction, sale or distribution of controversial weapons. The exclusion of identified securities follows a definedprocess incorporating Compliance, Research and Responsible Investment, increasing collaboration and researchintensity. Our procedures and exclusion list are reviewed and updated on an annual basis.

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Issued 06.24 | Valid to 06.25 | WF2298075