Adverse Impact Statement
Set out below is the way in which Russell Investments Limited, Russell Investments
Implementation Services Limited and Russell Investments Ireland Limited (together, “RussellInvestments”), consider the adverse impacts of its activities on sustainability factors.

Russell Investments is steward of its clients’ capital and takes seriously its commitment to respond to the mandates entrusted
to it by its clients. As standard practice across its portfolios, Russell Investments seeks to identify and manage financiallymaterial sustainability risks as detailed in its Sustainability Risk Policy. Adverse impacts and financially material sustainability
risks are not mutually exclusive, and those adverse impacts that overlap with sustainability risks are considered as standard
operating procedure.
Russell Investments also monitors and reports on a limited number of metrics related to adverse impacts in the equity asset
class, and for a limited number of portfolios outside of equities. In addition to monitoring and reporting, there are also
circumstances where Russell Investments incorporates explicit management of adverse impacts into a mandate.
Russell Investments differentiates between two levels of response to adverse impacts. The first is measuring and reporting on
adverse impacts. The second is explicitly managing adverse impacts.
a)Monitoring and reporting on adverse impacts

Russell Investments considers some specific adverse impacts metrices for the equity asset class as standard practice andthese metrices are monitored for all equity portfolios. This includes monitoring carbon emissions and an overall ESG score.
This information is made available to investment teams for their consideration and is an input into quarterly calls with itssubadvisors for the consideration of such subadvisors. It is also made available to clients. Russell Investments actively
investigates data offerings in other asset classes and will seek to expand reporting and monitoring of adverse impact metrices
to other metrics and asset classes over time as data availability and quality permits.
b)

Managing Adverse Impacts

Where agreed with a client or clearly stated in a fund’s objectives, Russell Investments explicitly manages some investment
portfolios to reduce one or more adverse impacts. Russell Investments employs various methodologies to do this including:i.

screening certain types of investments that are considered to have an adverse impact; orii.

centralised implementation of multi-manager portfolios, enabling Russell Investments to use an overlay to reduce
certain adverse impacts by shifting weight out of those securities with the highest adverse impacts.

Important information
FOR PROFESSIONAL CLIENTS ONLY
Unless otherwise specified, Russell Investments is the source of all data. All information contained in this material is current at the time of issue
and, to the best of our knowledge, accurate. Any opinion expressed is that of Russell Investments, is not a statement of fact, is subject to change
and does not constitute investment advice.
In the EU this marketing document has been issued by Russell Investments Ireland Limited. Company No. 213659. Registered in Ireland withregistered office at: 78 Sir John Rogerson’s Quay, Dublin 2, Ireland. Authorised and regulated by the Central Bank of Ireland. In the UK thismarketing document has been issued by Russell Investments Limited. Company No. 02086230. Registered in England and Wales withregistered office at: Rex House, 10 Regent Street, London SW1Y 4PE. Telephone +44 (0)20 7024 6000. Authorised and regulated by theFinancial Conduct Authority, 12 Endeavour Square, London, E20 1JN. In the Middle East this marketing document has been issued by Russell
Investments Limited a Dubai International Financial Centre company which is regulated by the Dubai Financial Services Authority at: Office 4,Level 1, Gate Village Building 3, DIFC, PO Box 506591, Dubai UAE. Telephone +971 4 578 7097.This material should only be marketed
towards Professional Clients as defined by the DFSA. KvK number 67296386©1995-2022 Russell Investments Group, LLC. All rights reserved.

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