Responsible
Investment
Engagement Policy
January 2024

Columbia Threadneedle Investments

PurposeThis Responsible Investment Engagement Policy is drafted andreviewed in accordance with regulatory requirements, including
those set out by Shareholder Directive, Directive (EU) 2017/828,
outlining our approach to and implementation of engagementby our Active Ownership1 team. The policy applies globally to
all Columbia Threadneedle Investments2 client accounts to theextent agreed upon or permissible. It also outlines our approachto engagement on behalf of reo®3 clients.
At Columbia Threadneedle Investments we strive to be
responsible stewards of our clients’ assets, , allocating theircapital within our framework of robust research and good
governance.

that we can play a part in building a more sustainable andresilient global economy by encouraging issuers to improve their
ESG practices. This can also help drive positive impacts for theenvironment and society that are in line with the achievement of
the United Nations Sustainable Development Goals (SDGs).
Our engagements focus on financial performance,sustainability risks and opportunities, operational excellence,
capital allocation policies and managerial incentives, among
other topics. Collaboration across asset classes and thematicand sectoral disciplines ensures an informed approach.
Our engagement programme is structured around seven highlevel themes:■ Climate change

We embrace our role as active investors to encourage positivechange both for our managed assets and reo® clients. We
dynamically interact with issuers to enhance their long-term
viability, performance, and sustainability to create value for ourclients as well as society.

■ Environmental stewardship, including biodiversity

Targeted Responsible Investment (RI) engagement with issuers
is an important part of our investment approach. Active
ownership enhances insights, encourages change, and helps
create future value. In addition, we believe that engagement
on environmental, social, and governance issues can havea positive impact on corporate performance and investment
returns, as well as on society or the environment.

■ Business conduct

Engagement definition

Engagement under this policy may cover listed equities;
corporate credit; Sovereign, Supranational and Agency(SSA) issuers; private equity; real estate; infrastructure;collateralized loan obligations; asset backed securities;municipal bonds; and commodities. For reo® clientsengagement under this policy covers listed equities, andcorporate (financial and non-financial) credit. In each case thisengagement activity is reinforced by the broader public policy
engagement undertaken for all our clients

We define engagement for the purposes of this policy as
having constructive dialogue with issuers on environmental,social and governance (ESG) risks that could have a material
negative impact on their businesses and, where necessary,
encouraging improvement in ESG management practices. Our
purpose with engagement is to support long-term investment
returns by mitigating risk, capitalising on opportunities linked to
ESG factors, and reducing any material negative impact that ourinvestment decisions could have on these factors. We believe■ Labour standards■ Human rights■ Public health■ Corporate governance.

Underlying each theme is a range of subthemes to help
focus our engagement. We monitor the outcomes of ourengagement and report on our progress to our clients andthrough public reporting.

The engagement programme’s scope is reviewed annually.

1

Active ownership is the use of the rights and position of ownership to encourage change in the activities or behaviour of issuers; it includes engagement and proxy voting activities. Active ownership canbe applied differently in each asset class.

2

Columbia Threadneedle Investments is the global brand name of the Columbia and Threadneedle group of companies that together make up the asset management business of Ameriprise Financial,
Inc. Individual client mandates or jurisdictional regulatory requirements may require a variation in approach. Any such variation in approach overrides this document as necessary.

3reo® is a pooled service that allows investors to receive engagement, and proxy voting where selected, on equity and corporate bond holdings, independent from portfolio management services received
either from third party asset managers or Columbia Threadneedle Investments.

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Columbia Threadneedle Investments

Commitments and related policies
In encouraging issuers to move towards best practice inmanaging ESG risks, we make reference to international codesand standards where relevant, such as the International Labour
Organization (ILO) Core Conventions, OECD Guidelines forMultinational Enterprises, UN Guiding Principles on Business andHuman Rights, the UN Global Compact, the Paris Agreement, theTaskforce on Climate-related Financial Disclosures, the Taskforce
on Nature-related Financial Disclosures, and national corporate
governance principles and codes of business best practice4. Our
key expectations on good practice are outlined in our corporate
governance guidelines5, and environmental and social practices
statements.

Policy and engagement programme implementation
Our engagement programme is executed through close
collaboration by our Active Ownership Analysts, comprisedof experienced engagement and voting specialists, with
Fundamental Research Analysts and portfolio managers.

Engagement identification, prioritization, and process
Bottom-up: priority issuers
We identify and prioritize issuers for engagement based on thefollowing:■ Assessment of impact of ESG risk and opportunity factors

now and in the future, including financial materiality of risk
issues in accordance with SASB Standards6■ Investment teams’ and Fundamental Analysts’ judgement

and expertise,■ Previous engagement track record■ The significance, probability of occurrence, and severity ofadverse sustainability impacts, including their potentiallyirremediable character, scale (gravity), scope and character(noting whether remedial action is possible);■ Assessment of likelihood of success for engagement;■ Level of exposure, typically based on size of holding acrossboth managed client assets and reo® client assets; and■ Overall preferences7 of managed clients or reo® clients as

may be provided to us

Additional considerations may be brought in depending on
the issue under engagement, such as specialist data sources
to identify issuers subject to a specific risk we are focusing
on. This includes engagement projects (see below), and our
Net Zero climate change engagement, which is prioritizedaccording to a set of factors including financed emissions
intensity and the quality of climate strategy.
We set specific engagement objectives (“Objectives”) and trackprogress against these to assess achievements (“Milestones”)
and determine next steps. When we open discussions withindividual issuers, we aim to clearly communicate our Objectives– including timelines, and desired outcomes.
Top-down: engagement projects
On an annual basis, the Active Ownership team conducts
a high-level assessment of a wide range of current andemerging ESG issues and their potential impacts on long-term
investment returns, the economy, environment, and society.
The results of this assessment determine the specific ESG
issues on which we will focus our engagement activities
going forward. Project-based engagements on specific issues
normally run for two to three years and are concluded by a final
assessment of progress.
Event-driven engagement
Part of our engagement happens in reaction to scheduled
events such as annual general meetings, where we would
outline shareholder expectations, and request changes toan issuer’s operations, governance structure or strategic
approaches. Engagement activity may also occur in response
to unscheduled and controversial events, such as scandals or
major environmental disasters linked to corporate operations.
Our event-driven engagement also occurs in reaction topotential issuer breaches of global standards, such as theOECD guidelines for multinational enterprises or the UN Global
Compact.
Engagement for specific mandates, fund strategy, or regulatory
requirements8
Individual client mandates, fund strategies or jurisdictional
regulatory requirements may require a dedicated approach toengagement that is different to the approach outlined above.
This will be outlined in client mandate documentation and/or
fund/strategy-specific investment policies.

For a full, current list, please see our Stewardship Report.
Columbia Threadneedle Investments Corporate Governance Guidelines can be found here.
Sustainability Accounting Standards Board https://www.sasb.org/
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Including annual reo® client consultation on company and thematic priorities, bespoke engagement requests or dedicated engagement mandates
8This does not apply to reo® clients given the nature and scope of the service.
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Columbia Threadneedle Investments

Conducting engagement
Our preferred approach to conducting engagement is to use
constructive, confidential dialogue, typically interacting one-toone with issuers and building a relationship of trust over time as
long-term investors. When it is more effective to take acollaborative approach to bring about change, we may form or
join coalitions with other investors, non-governmentalorganisations (NGOs) or industry groups, whilst ensuring that we
adhere to all applicable anti-trust competition legal andregulatory requirements and any other applicable limitations
when doing so. We have an internal Addendum to the RIEngagement Policy on collaborative engagement, detailing further
requirements.
Speaking with a unified voice can allow investors to communicate
their concerns more effectively, whilst gaining power andlegitimacy from the perspective of corporate management.
Furthermore, collaborations can help build knowledge and skills
whilst enhancing engagement efficiency. We are a member ofseveral investor coalitions actively pursuing collaborative
engagements9. We engage at different levels within issuers
depending on the nature of our Objectives, including with theboard, executive management, investor relations, sustainability
leadership, and operational specialists.

Public policy engagement
We recognise that action by governments or regulatoryintervention is also often needed to create a level playing
field and achieve meaningful results. To that end, we aspire
to play an active role in public policy development throughengagement with policymakers and regulators. We seek tobring a constructive investor voice to standard settings, andwe believe that policy and regulatory change is often the
catalyst for improved corporate behaviour.

Escalationassess progress against the Objectives we have set for eachissuer we engage with. We also assess annually all issuers’
responsiveness to engagement undertaken in the previous full
year. Both data points feed into the escalation decision.
Escalation activity takes place in collaboration with otherinvestment to ensure agreement on the need for escalation andalignment on avenues to pursue departments within Columbia
Threadneedle Investments.
As stewards of our clients’ investments, we have at our disposal
several different options for escalation, which include:■ Collaborative engagement10: While we generally prefer toengage issuers in private to enable honest, open, and frank
discussions to take place, collaboration with other investors
or stakeholders, might be an impactful engagement or
escalation strategy. Given ownership of an issuer is often
dispersed, for a stakeholder’s voice to have weight it may
require collaborative engagement to address issues
effectively at the issuer or industry level. We support
dialogue amongst investors and collaborative engagement
where this contributes to the creation and protection of
stakeholder value.
■ Public statements: For both equity and corporate credit

escalation issuing a public statement outlining disagreementwith management’s approach and formulating ESG bestpractices and expectations is an additional escalation
option.
■ Filing shareholder resolutions: Filing an equity or bondholder

resolution can be a key rallying point of an engagement
campaign to change issuers’ behaviour. Examples might
include improving board accountability, executive pay
practices, ESG-related disclosure, climate change action or
employee welfare.
■ Annual General Meetings (AGMs): Requesting a shareholder

meeting or intervening at an AGM offer the opportunity fordirect, public dialogue with boards and top executives.
Interventions at AGMs can also trigger further dialogue with
an issuer, paving the way to more in-depth engagement on
an issue.

If issuers do not demonstrate progress on matters that we
believe are in our clients’ best long-term economic interests,
we may consider further escalation.

■ Proxy voting: Voting against management on key resolutions

In considering engagement escalation strategies, we will makea case-by-case assessment of progress against our Objectives
and how issuers respond to our engagement. Assessments
take place at quarter end when Active Ownership analysts■ Partial or complete divestment11: Re-weighting a position tosends a clear signal to issuers and can help with further
engagement efforts.
reflect the investment risk of poor ESG practices or selling aholding outright can be a powerful signal of dissatisfaction in
response to inadequate progress against Objectives.

These memberships and initiatives may change over time and the current list is disclosed in the annual Stewardship Report available here.
Collaborative engagement is not exclusively used for escalation purposes but can also be used as standard engagement with other investors.
11This does not apply to reo® clients given the nature and scope of the service. reo® clients may choose to take this path themselves in response to our assessment of inadequate progress against
engagement Objectives.
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Columbia Threadneedle Investments

Tracking engagement progress
Objectives, Engagement Activity and Milestones are tracked andmonitored for ESG-focused engagements. All engagement istracked in a company-wide database and accessible to all
research analysts and portfolio managers.
The database allows us to produce engagement activity reports
for internal use, clients, or the general public, e.g. our
Stewardship Report.

as well as our public policy engagement, reflecting our full sphereof influence. We do this via quarterly and annual stewardshipreports that we make publicly available on our website12. We also
publish research and thought leadership pieces on specificengagement activities and ESG topics; and ESG profile andimpact reports for a number of funds that contain information on
engagement. These are all available on our website.

Conflicts of interest

We measure and report on the success of engagement throughthe assignment of “Milestones”, which recognize improvements
in issuers’ ESG policy, management systems or practices against
the Objectives that were set. Milestones are ascribed using athree-star rating system, with three stars indicating the mostmaterial changes of significant ESG impact and one starreflecting smaller, incremental change to ESG practices along apathway for the issuer, or across a broader context, for the
relevant industry as a whole.

Although we seek to act in the best interests of our managed
asset and reo® clients, we recognize that certain conflicts ofinterest may arise due to our engagement activities
contemplated by this policy. Our approach to identify, prevent,and/ or manage potential conflicts to ensure we serve ourclients’ best interests is guided by various conflicts of interest
policies in place across Columbia Threadneedle Investments
including specifically around conflicts arising in respect of Active
Ownership – Engagement13.

Active Ownership analysts also assign an annual “ResponsivenessRating” to issuers engaged.

Governance of the Responsible Investment Engagement Policy

Transparency
Clear accountability and transparent communication are key
elements of our Responsible Investment engagement
programme. We report periodically on the number ofengagements, the number of successful engagement outcomes,

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The Responsible Investment Engagement Policy is reviewed
annually by the Responsible Investment team, the GeneralCounsel’s Organisation (GCO) and other relevant stakeholders,
including Investments. The internal governance committees
approve any updates to policy and its underlying principles andprocesses.

Stewardship Reports can be found here.
See Conflicts of Interest Addendum – Active Ownership: Engagement

5Contact us
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To find out more visit columbiathreadneedle.com© 2024 Columbia Threadneedle Investments is the global brand name of the Columbia and Threadneedle group of companies.
Important Information: This communication is valid at the date of publication and may be subject to change without notice.

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