Conflicts of Interest
Addendum
Proxy Voting
January 2024

Columbia Threadneedle Investments

Introduction
At Columbia Threadneedle Investments, we seek to act in the best interests of our clients in ourinvestment management business in line with our stewardship obligations. We recognise conflicts ofinterest may arise in our investment activities and any services we provide. We seek to identify, andthen prevent and/or manage conflicts to serve our clients’ best interests.

This is an addendum to our Responsible Investment Proxy
Voting Policy, outlining our approach to and implementationof proxy voting. It outlines how we deal with certain potential
conflicts between our interests and those of our clients, orbetween the interests of two or more clients, and across all
asset classes between teams who are involved in proxy voting(being our Active Ownership (AO) team, who implement our
proxy voting process and the execution of votes, and otherteams within Columbia Threadneedle Investment (Research,Portfolio Management) who are also involved in this activity.
This addendum does not represent a complete list of all
potential conflicts relevant to our proxy voting activity; rather
it sits alongside our wider conflicts of interest policies
referenced below under which all potential and actual conflictsof interest identified are monitored, managed and/or mitigatedacross the organisation. From time to time, we may need toadjust our approach to dealing with conflicts from that outlined
below to deal with the issues raised by a particular set ofcircumstances.

Voting the meeting of an issuer who is also a client

objectives and best interests (including best long-term
economic interest).
Columbia Threadneedle Investment’s Responsible Investment(RI) Corporate Governance and Proxy Voting frameworks aredeveloped and executed by the Active Ownership (AO) teamwith input from internal Fundamental Research Analysts
and portfolio managers, who maintain the ability to request
overrides over the standard votes cast in relation to theirfund holdings through our Proxy Voting Working Group. OurCorporate Governance Guidelines are available on our website
and provide further detail on our stance around corporate
governance best practice. They are further supplemented byour Proxy Voting Policy, which provides additional detail on theoperation of the Proxy Voting framework.

Proxy Voting of an issuer involving an Officer, Directoror Employee of Ameriprise Financial, Inc or any of its
subsidiaries (“Officer, Director, or Employee”)
We may maintain a proxy voting position in an issuer where anOfficer, Director or Employee serves on the board of that issuer.

We may vote at the shareholder meeting, of an investee issuer
where the issuer (or a related party such as a sponsoredpension scheme) is also a client.

We manage this conflict by ensuring that all such votes arealways instructed by following the automated vote submission
from the proxy voting service provider which explicitly follows
own Corporate Governance Guidelines.

We treat all our clients equally in our proxy voting activities.
We do not alter our position due to a business relationshipthat an issuer may have with us or any other part of the wider
Ameriprise Financial, Inc. group although we may collaborate
with other business areas within Columbia Threadneedle
Investments or the wider Ameriprise Financial, Inc. aspart of the effective management of any potential conflictarising because of such a business relationship. Unless
an institutional client instructs us otherwise, we apply ourCorporate Governance Guidelines1 to all client portfolios ina manner that considers our clients’ respective investment

Additionally, we apply this and other Columbia Threadneedle
Investment policies specifically relating to Officers, Directors,
or Employees with relationships with investee companies.
For example, Columbia Threadneedle Investment’s Global
Policy – Outside Activities and Family Relationships requires
our employees to declare and disclose their outside businessinterests. In cases where there is a significant conflict, we may
determine that it is inappropriate for such employees, who may
also determine the same given their own personal position, todirect proxy voting with certain investee companies.

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Including: applicable RI investment policies, Engagement Policy, Proxy Voting Policy, Environmental and Social Practices StatementsColumbia Threadneedle Investments

Proxy Voting to favour one client over another:
Potential conflicts of interest could arise where we vote at
an issuer on a matter with a potential outcome that favours oneclient 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, weapply our Corporate Governance Guidelines to all client
portfolios in a manner that considers our clients’ respective
investment objectives and best interests. This could resultin our acting on a matter in the same or a different way forvarious clients.
Clients also can provide us with written instruction on how
to vote specific meetings.

considered but does not occur at the expense of the best
economic interest of our clients. We seek to treat all clientsequally in our proxy voting activities.

Other conflict management tools in Active Ownership –Proxy Voting:Proxy Voting to favour one Active Ownership Analyst or Portfolio
Manager or Fundamental Research Analyst over Another:
Potential conflicts of interest could arise within or between teamsof AO analysts, portfolio managers or fundamental researchanalysts, where there is a lack of consensus on how to votespecific proposals at a shareholder meeting.
We manage this potential conflict through our Proxy Voting
framework, whereby conflicts may be escalated to the Proxy
Working Group, for resolution and, if necessary, ultimately to therelevant regional internal investment committee. More detailon this is provided in the Proxy Voting Policy. The AO Team also
notifies all portfolio managers and fundamental research analysts
of upcoming meetings that require a vote, in accordance with
our prioritisation process, whereby concerns over specific votedirections can be raised to the AO team for further analysis.
Regular exchanges between Fundamental Research analysts,
portfolio managers and the AO team take place to understand andalign on respective proxy voting efforts.
The internal consultation process allows divergent views to beOur AO Team: We have a team of ESG experts who work
alongside, but independently from, the fundamental
research and portfolio management teams. The AO teamleads the development of our Corporate Governance
Guidelines with input from portfolio managers andresearch analysts and undertakes proxy voting activitiesas well as research and analysis.
Oversight: The relevant internal regional investmentcommittees oversee this policy to ensure Columbia
Threadneedle Investments effectively addresses
conflicts of interests connected with proxy voting. OurCompliance department, as well as, where applicable,
our investment fund boards may also periodically review
our compliance with this policy.
Our Compliance and Data Protection Systems: We havestrict firewalls to keep client holdings data confidential
and always protected, separating holdings of clients withmanaged portfolios from those of clients who subscribeonly to our reo® services.
Transparency and Disclosure: We seek to upholdhigh standards in transparency and disclosure toenable clients and broader stakeholders to review
our effectiveness in managing conflicts. Our regular
reporting to clients includes both our public vote recordand our annual Stewardship Code report on Columbia
Threadneedle Investment’s Active Ownership activities
with issuers and public policy makers.
Conflicts of Interest Policy: Columbia Threadneedle
Investments maintains wider conflicts of interest policies
under which all potential and actual conflicts of interest
identified are monitored, managed and/or mitigated.

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