PUBLIC RI REPORT
2021 PILOT
Russell Investments
Generated 2022-08-18

About this report
The PRI Reporting Framework helps to build a common language and industry standard for reporting responsible investment
activities. Public RI Reports provide accountability and transparency on signatories’ responsible investment activities and support
dialogue within signatories’ organisations, as well as with their clients, beneﬁciaries and other stakeholders.
This Public RI Report is an export of the signatory’s responses to the PRI Reporting Framework during the 2021 reporting period. It
includes the signatory’s responses to mandatory indicators, as well as responses to voluntary indicators that the signatory has agreed
to make public.
The information is presented exactly as it was reported. Where an indicator offered a multiple-choice response, all options that wereavailable to select from are included for context. While presenting the information verbatim results in lengthy reports, the approach isinformed by signatory feedback that signatories prefer that the PRI does not summarise the information.

Context
In consultation with signatories, between 2018 and 2020 the PRI extensively reviewed the Reporting and Assessment processes and set
the ambitious ob jective of launching in 2021 a completely new investor Reporting Framework, together with a new reporting tool.
We ran the new investor Reporting and Assessment process as a pilot in its ﬁrst year, and such process included providing additional
opportunities for signatories to provide feedback on the Reporting Framework, the online reporting tool and the resulting reports. The
feedback from this pilot phase has been, and is continuing to be analysed, in order to identify any improvements that can be includedin future reporting cycles.

PRI disclaimer
This document presents information reported directly by signatories in the 2021 reporting cycle. This information has not been
audited by the PRI or any other party acting on its behalf. While this information is believed to be reliable, no representations or
warranties are made as to the accuracy of the information presented.
The PRI has taken reasonable action to ensure that data submitted by signatories in the reporting tool is reﬂected in their oﬃcial PRI
reports accurately. However, it is possible that small data inaccuracies and/or gaps remain, and the PRI shall not be responsible or
liable for such inaccuracies and gaps.

2

Table of Contents
Module/Indicator

Page

Senior Leadership Statement (SLS)4

Organisational Overview (OO)

8

Investment and Stewardship Policy (ISP)

35

Manager Selection, Appointment and Monitoring (SAM)

77

Listed Equity (LE)97

Sustainability Outcomes (SO)115

3

Senior Leadership Statement (SLS)
Senior leadership statement
Our commitment
Indicator

Type of indicator

Dependent on

Gateway toDisclosure

Subsection

PRI Principle

SLS 1 S1

CORE

N/A

N/A

PUBLIC

Our commitment

GENERALWhy does your organisation engage in responsible investment?
What is your organisation’s overall approach to responsible investment?
What are the main differences between your organisation’s approach to responsible investment in its ESG practice and inother practices, across asset classes?

Responsible investing is at the heart of our ﬁrm’s growth strategy and our vision to provide world-class responsible investing solutions,with a clear focus on creating investment value. Everyday, we seek to improve the ﬁnancial security of our clients. Our purpose of
improving people’s ﬁnancial security means we must be effective stewards of assets so that we create long-term value for our clients andtheir beneﬁciaries. We believe in an integrated approach to responsible investing. It is vital for asset owners to understand the impact ofenvironmental, social and governance (ESG) characteristics on security prices and markets when building an investment portfolio. As a
global investment solutions provider, we have found that investing responsibly can help deliver attractive investment returns and meetclient objectives in the long-term. To reﬂect this, we have based our responsible investing practice on a set of four beliefs: 1. ESG
factors impact security prices. These factors can vary by company, industry, and region and their importance can vary through time.
2. A deep understanding of how ESG factors impact security prices is value-adding to a skilful investment process. 3. Embedding ESG
considerations into the ﬁrm's culture and processes improves the likelihood of prolonged and successful investing. 4. Active ownershipof securities is an effective tool for improving investment outcomes. Russell Investments’ policy is to integrate sustainability risks in ourinvestment solutions by identifying, evaluating and managing relevant risks in our investment manager review process, portfolio
management and through implementing proprietary solutions. We believe that sustainability risks are most relevant to investment
outcomes when they exhibit ﬁnancial materiality and like all investment risks, are incorporated by balancing expected risk withexpected reward. In managing investment solutions, we consider ﬁnancially-material sustainability risks in the context of expected
rewards using a blend of inputs from sources including, but not limited to, investment managers, third-party data sources and Russell
Investments proprietary analysis. Furthermore, we incorporate bespoke sustainability risks based on clients’ requirements for customised
mandates. Additionally, we seek to collaborate with our advisory clients to consider, monitor and manage sustainability risk priorities intheir portfolios. Our tenets and beliefs drive our policies and our investment practices, and ultimately reﬂect how we act as responsible
stewards of assets to create long term value for our clients and beneﬁciaries.

4

Annual overview
Indicator

Type of indicator

Dependent on

Gateway toDisclosure

Subsection

PRI Principle

SLS 1 S2

CORE

N/A

N/A

PUBLIC

Annual overview

GENERAL

Discuss your organisation’s progress during the reporting year on the responsible investment issue you consider most
relevant or material to your organisation or its assets.
Reﬂect on your performance with respect to your organisation’s responsible investment ob jectives and targets during thereporting year. This might involve e.g. outlining your single most important achievement, or describing your generalprogress, on topics such as the following:
reﬁnement of ESG analysis and incorporation
stewardship activities with investees and/or with policy makers
collaborative engagements
attainment of responsible investment certiﬁcations and/or awards

We have made signiﬁcant strides in enhancing our integrated approach to responsible investing over the last year. Our CEO identiﬁed
responsible investing as one of four global strategic initiatives in 2020. We also conducted a comprehensive data-driven analysis toevaluate our offering and capabilities. The recommendations from this review were subsequently reviewed by an external consulting ﬁrm.
The proposed enhancements from this strategic review covers multiples areas of our business including: 1. Enhanced governancearound advancing our responsible investing practices 2. Improved integrated approach within our investment function 3. Focus on
climate risk assessment 4. Enhancements to our active ownership practices 5. Increased focus on ESG considerations within our manager
research ranking process 6. Increased focus on training for associates globally, education, and materials 7. Increased dedicatedresourcing to further all of our responsible investing efforts We will be actively embedding these enhancements over the course of 2021.

5

Next steps
Indicator

Type of indicator

Dependent on

Gateway toDisclosure

Subsection

PRI Principle

SLS 1 S3

CORE

N/A

N/A

PUBLIC

Next steps

GENERAL

What speciﬁc steps has your organisation outlined to advance your commitment to responsible investment in the next two
years?
As an organization we have taken multiple steps to advance our commitment to responsible investment as detailed in our response to
Section 2. These enhancements will require both additional staff and investment in data and systems. This clearly demonstrates theexecutive teams’ commitment to advancing our overall proposition. A number of these initiatives are multi year in nature and will taketime to complete.

Endorsement
Indicator

Type of indicator

Dependent on

Gateway toDisclosure

Subsection

PRI Principle

SLS 1 S4

CORE

N/A

N/A

PUBLIC

Endorsement

GENERAL

The Senior Leadership Statement has been prepared and/or reviewed by the undersigned and reﬂects our organisation-widecommitment and approach to responsible investment.

Name

Kate El-Hillow

Position

Global Chief Investment Oﬃcer

Organisation's name

Russell Investments◉ This endorsement is for the Senior Leadership Statement only and is not an endorsement of the information reported byRussell Investments in the various modules of the Reporting Framework. The Senior Leadership Statement is simply provided asa general overview of Russell Investments's responsible investment approach. The Senior Leadership Statement does notconstitute advice and should not be relied upon as such, and is not a substitute for the skill, judgement and experience of any
third parties, their management, employees, advisors and/or clients when making investment and other business decisions.

6Organisational Overview (OO)
Organisational information
Categorisation
Indicator

Type ofindicator

Dependent on

Gateway toDisclosure

Subsection

PRI
Principle

OO 1

CORE

Signatory
category

Multiple, seeguidance

PUBLIC

Categorisation

GENERAL

Select the type that best describes your organisation or the services you provide.

(O) Fund management(2) This is an additional(secondary) type(P) Fund of funds, manager of managers or sub-advised products(1) This is our only (or primary)type(Q) Execution and advisory(2) This is an additional(secondary) type(R) Wealth management(2) This is an additional(secondary) type(S) Fiduciary management or other outsourced discretionary fund allocation(2) This is an additional(secondary) type7

Subsidiary information
Indicator

Type of indicator

Dependent on

Gateway toDisclosure

Subsection

PRI Principle

OO 2

CORE

N/A

OO 2.1

PUBLIC

Subsidiary information

GENERAL

Does your organisation have subsidiaries that are also PRI signatories in their own right?
○ (A) Yes
◉ (B) No

Reporting year
Indicator

Type of indicator

Dependent on

Gateway toDisclosure

Subsection

PRI Principle

OO 3

CORE

N/A

N/A

PUBLIC

Reporting year

GENERAL

Indicate the year-end date for your reporting year.

Reporting year end date:

Month

Day

Year

December

31

2020

8

Assets under management
All asset classes
Indicator

Type of indicator

Dependent on

Gateway toDisclosure

Subsection

PRI Principle

OO 4

CORE

OO 4.1, OO 4.2

N/A

PUBLICAll asset classes

GENERAL

What were your total assets under management (AUM) at the end of the indicated reporting year? Provide the amount in USD.

(A) AUM of your organisation,
including subsidiaries

US$ 216,634,000,000.00(B) AUM of subsidiaries that are
PRI signatories in their own rightand excluded from this submission

US$ 0.00(C) AUM sub ject to execution,
advisory, custody, or researchadvisory only

US$ 2,840,655,000,000.00

Asset breakdown
Indicator

Type ofindicator

Dependent on

Gateway toDisclosure

Subsection

PRI
Principle

OO 5

CORE

Multiple, seeguidance

Multiple, seeguidance

PUBLICAsset
breakdown

GENERAL

Provide a percentage breakdown of your total assets under management at the end of your indicated reporting year.
Percentage of AUM(A) Listed equity – internal

0-10%(B) Listed equity – external

50-75%(C) Fixed income – internal

0-10%

9

(D) Fixed income – external

10-50%(E) Private equity – internal

0.0%(F) Private equity – external

0-10%(G) Real estate – internal

0.0%(H) Real estate – external

0-10%(I) Infrastructure – internal

0.0%(J) Infrastructure – external

0-10%(K) Hedge funds – internal

0.0%(L) Hedge funds – external

0-10%(M) Forestry – internal

0.0%(N) Forestry – external

0.0%(O) Farmland – internal

0.0%(P) Farmland – external

0.0%(Q) Other – internal, please specify:
Commodities, currency, cash, otheralternatives

0-10%(R) Other – external, please specify:

0.0%(S) Off-balance sheet – internal

0.0%(T) Off-balance sheet – external

0.0%

10

IndicatorType ofindicator

DependentonGateway toDisclosure

Subsection

PRI Principle

OO 5.1CORE

OO 5

Multiple, seeguidance

PUBLICAsset
breakdown

GENERAL

Provide a breakdown of your organisation's externally managed assets between segregated mandates and pooled funds orinvestments.
(1)
Listedequity(2)
Fixedincome(3)
Privateequity(4) Real
estate(5)Infrastru
cture(6) Hedge
funds(A) Segregated mandate(s)10-50%

10-50%

50-75%

10-50%

0-10%

>75%

(B) Pooled fund(s) or pooled
investment(s)50-75%

50-75%

10-50%

50-75%>75%

10-50%

Indicator

Type ofindicator

DependentonGateway toDisclosure

Subsection

PRI Principle

OO 5.2 LE

CORE

OO 5, OO 5.1

Multiple, seeguidance

PUBLICAsset
breakdown

GENERAL

Provide a further breakdown of your listed equity assets.

(A) Internal allocation(B) External allocation– segregated(C) External allocation –pooled(1) Passive equity

0.0%

0.0%

0.0%

(2) Active – quantitative

>75%

0-10%

0-10%

(3) Active – fundamental

0.0%

>75%

>75%

(4) Investment trusts (REITs andsimilar publicly quoted vehicles)

0.0%

0-10%

0-10%

(5) Other, please specify:

0.0%

0.0%

0.0%

11

IndicatorType ofindicator

DependentonGateway toDisclosure

Subsection

PRI Principle

OO 5.2 FI

CORE

OO 5, OO 5.1

Multiple, seeguidance

PUBLICAsset
breakdown

GENERAL

Provide a further breakdown of your ﬁxed income assets.

(A) Internal allocation(B) External allocation– segregated(C) External allocation –pooled(1) Passive – SSA

50-75%

0.0%

0.0%(2) Passive – corporate

10-50%

0.0%

0.0%(3) Passive – securitised

0.0%

0.0%

0.0%

(4) Active – SSA

0.0%

10-50%

10-50%(5) Active – corporate

0.0%

10-50%

10-50%(6) Active – securitised

0.0%10-50%

10-50%(7) Private debt

0.0%

0-10%

0.0%

Indicator

Type of indicator

Dependent on

Gateway toDisclosure

Subsection

PRI Principle

OO 5.2 PE

CORE

OO 5, OO 5.1

N/A

PUBLIC

Asset breakdown

GENERAL

Provide a further breakdown of your private equity assets.
(B) External allocation – segregated(C) External allocation – pooled(1) Venture capital

0.0%

0-10%

(2) Growth capital

0.0%

0-10%

(3) (Leveraged) buyout

0.0%

10-50%

12

(4) Distressed, turnaround or
special situations

0.0%

10-50%(5) Secondaries

0.0%

0-10%

(6) Other, please specify:>75%

50-75%

Indicator

Type of indicator

Dependent on

Gateway toDisclosure

Subsection

PRI Principle

OO 5.2 RE

CORE

OO 5, OO 5.1

N/A

PUBLIC

Asset breakdown

GENERAL

Provide a further breakdown of your real estate assets.
(B) External allocation – segregated(C) External allocation – pooled(1) Retail10-50%

10-50%(2) Oﬃce

10-50%

10-50%(3) Industrial

10-50%

10-50%(4) Residential

10-50%

10-50%(5) Hotel

0.0%

0.0%

(6) Lodging, leisure and recreation

0-10%

0-10%

(7) Education

0.0%

0.0%

(8) Technology/science

0.0%

0.0%

(9) Healthcare

0-10%

0-10%

(10) Mixed use

0-10%

0-10%

(11) Other, please specify:

0-10%

0-10%

13

IndicatorType of indicator

Dependent on

Gateway toDisclosure

Subsection

PRI Principle

OO 5.2 INF

CORE

OO 5, OO 5.1

N/A

PUBLIC

Asset breakdown

GENERAL

Provide a further breakdown of your infrastructure assets.
(B) External allocation – segregated(C) External allocation – pooled(1) Data infrastructure

0.0%

0.0%

(2) Energy and water resources

0.0%

0.0%

(3) Environmental services

0.0%

0.0%

(4) Network utilities

0.0%

0.0%

(5) Power generation (excl.
renewables)

0.0%

0.0%

(6) Renewable power

0-10%

0-10%

(7) Social infrastructure

0-10%

0-10%

(8) Transport

0.0%

0.0%

(9) Other, please specify:

>75%

>75%

Indicator

Type of indicator

Dependent on

Gateway toDisclosure

Subsection

PRI Principle

OO 5.2 HF

CORE

OO 5, OO 5.1

OO 9 HF, OO 10

PUBLIC

Asset breakdown

GENERAL

Provide a further breakdown of your hedge fund assets.
(B) External allocation – segregated(C) External allocation – pooled(1) Multi strategy

10-50%

10-50%(2) Long/short equity

10-50%

10-50%

14

(3) Long/short credit

10-50%

10-50%(4) Distressed, special situations
and event-driven fundamental

0-10%

0-10%

(5) Structured credit

10-50%

10-50%(6) Global macro

10-50%

10-50%(7) Commodity trading advisor

0-10%

0-10%

(8) Other, please specify:

10-50%

10-50%

ESG strategies
Listed equity
Indicator

Type of indicator

Dependent on

Gateway toDisclosure

Subsection

PRI Principle

OO 6 LE

CORE

OO 5.2 LE

OO 6.1 LE, LE 13

PUBLIC

Listed equity

1

Which ESG incorporation strategy and/or combination of strategies do you apply to your internally managed active listed
equity?
Percentage out of total internally managed active listed equity:(A) Screening alone

0.0%(B) Thematic alone

0.0%(C) Integration alone

0.0%(D) Screening and integration>75%(E) Thematic and integration

0.0%(F) Screening and thematic

0.0%(G) All three strategies combined

0.0%

15

(H) None

0.0%

Indicator

Type of indicator

Dependent on

Gateway toDisclosure

Subsection

PRI Principle

OO 6.1 LE

CORE

OO 6 LELE 8

PUBLIC

Listed equity

1

What type of screening is applied to your internally managed active listed equity assets?
Percentage coverage out of your total listed equities where screening strategy is applied(A) Positive/best-in-class screening
only

0.0%

(B) Negative screening only

50-75%(C) A combination of positive/bestin-class and negative screening

25-50%

Externally managed assets
Indicator

Type ofindicator

Dependent on

Gateway toDisclosure

Subsection

PRI
Principle

OO 6 SAM

CORE

OO 5.2 LE, OO 5.2
FI

OO 6.1SAM

PUBLIC

Externally managed
assets1

Which ESG incorporation strategy and/or combination of strategies apply to your externally managed active listed equity andﬁxed income?

(1) Listed equity- external(2) Fixed income– SSA - external(3) Fixed income– corporate external(4) Fixed income –securitised external(A) Screening alone

0.0%

0.0%

0.0%

0.0%

(B) Thematic alone

0.0%

0.0%

0.0%

0.0%

(C) Integration alone

>75%

>75%

>75%

>75%

16

(D) Screening and integration

0-25%

0.0%

0.0%

0.0%

(E) Thematic and integration

0.0%

0.0%

0.0%

0.0%

(F) Screening and thematic

0-25%

0.0%

0.0%

0.0%

(G) All three strategies combined

0-25%

0.0%

0.0%

0.0%

(H) None

0.0%

0.0%

0.0%

0.0%

Indicator

Type of indicator

Dependent on

Gateway toDisclosure

Subsection

PRI Principle

OO 6.1 SAM

CORE

OO 6 SAM

N/A

PUBLIC

Externally managed assets

1

What type of screening is applied to your externally managed active listed equity and ﬁxed income?
(1) Listed equity - external(A) Positive/best-in-class screening
only

0.0%

(B) Negative screening only

50-75%(C) A combination of positive/bestin-class and negative screening

25-50%

17

Externally managed assets
Captive relationships
Indicator

Type ofindicator

DependentonGateway toDisclosure

Subsection

PRI
Principle

OO 7

CORE

OO 5

Multiple, seeguidance

PUBLIC

Captiverelationships

GENERAL

Does your organisation have a captive relationship with some or all of its external investment managers?
○ (A) Yes
◉ (B) No

Investment consultants
Indicator

Type of indicator

Dependent on

Gateway toDisclosure

Subsection

PRI Principle

OO 8

CORE

OO 5

SAM 1

PUBLIC

Investment consultants

GENERAL

Does your organisation engage investment consultants in the selection, appointment or monitoring of your external investment
managers?
○ (A) Yes
◉ (B) No18

Stewardship
Listed equity
Indicator

Type ofindicator

Dependent on

Gateway toDisclosure

Subsection

PRI Principle

OO 9 LE

CORE

OO 5, OO 5.2
LE

Multiple, see guidance

PUBLIC

Listed equity

2

Does your organisation conduct stewardship activities for your listed equity assets?
(1) Engagement on listed equity –active(3) (Proxy) voting on listed equity –active(A) Through service providers☑

☑

(B) Through external managers☐☐(C) Through internal staff☑

☑

(D) Collaboratively☑

☑

(E) We did not conduct thisstewardship activity☐☐

Fixed income
Indicator

Type of indicator

Dependent on

Gateway toDisclosure

Subsection

PRI Principle

OO 9 FI

CORE

OO 5, OO 5.2 FI

Multiple, see guidance

PUBLIC

Fixed income

2

Does your organisation conduct stewardship activities for your ﬁxed income assets?

(A) Through service providers(1)
Passive– SSA(2)
Passive –corporate(4)
Active –SSA(5)Active –corporate(6) Active–
securitised(7) Private
debt

☐

☐

☐

☐

☐

☐

19

(B) Through external managers

☐

☐

☐

☐

☐

☐

(C) Through internal staff

☐

☐

☐

☐

☐

☐

(D) Collaboratively

☐

☐

☐

☐

☐

☐

(E) We did not conduct thisstewardship activity for thisstrategy/asset type

☑

☑

☑

☑

☑

☑

Private equity, real estate and infrastructure
Indicator

Type ofindicator

DependentonGateway toDisclosure

Subsection

PRI
Principle

OO 9 ALT

CORE

OO 5

Multiple, seeguidance

PUBLICPrivate equity, real estate andinfrastructure

2

Does your organisation conduct stewardship activities in the following asset classes?
(1) Private equity(2) Real estate(3) Infrastructure(A) Through service providers

☐

☐

☐

(B) Through external managers

☐

☐

☐

(C) Through internal staff

☐

☐

☐

(D) Collaboratively

☐

☐

☐

(E) We did not conduct
stewardship activities for this asset
class

☑

☑

☑

20

Hedge funds
Indicator

Type of indicator

Dependent on

Gateway toDisclosure

Subsection

PRI Principle

OO 9 HF

CORE

OO 5, OO 5.2 HF

Multiple, see guidance

PUBLIC

Hedge funds

2

Does your organisation conduct stewardship activities for your hedge fund assets?
(1) Engagement(2) (Proxy) voting(A) Through service providers☐☐(B) Through external managers☐☐(C) Through internal staff☐☐(D) Collaboratively☐☐(E) We did not conduct thisstewardship activity☑

☑

ESG incorporation
Internally managed assets
Indicator

Type ofindicator

Dependent on

Gateway toDisclosure

Subsection

PRI
Principle

OO 10

CORE

Multiple, seeguidance

Multiple, seeguidance

PUBLICInternally managed
assets1

For each internally managed asset class, select whether or not you incorporate ESG into your investment decisions.

(B) Listed equity – active –quantitative(1) ESG incorporated into investment
decisions(2) ESG not incorporated into investment
decisions

◉

○

21

(F) Fixed income – SSA○◉(G) Fixed income – corporate○◉(W) Other [as speciﬁed]○◉

External manager selection
Indicator

Type ofindicator

Dependent on

Gateway toDisclosure

Subsection

PRI
Principle

OO 11

CORE

Multiple, seeguidance

Multiple, seeguidance

PUBLIC

External manager
selection

1

For each externally managed asset class, select whether or not you incorporate ESG into external manager selection. Your
response should refer to the selection of the external managers who managed the relevant asset classes during the reporting year,
regardless of when such selection took place.
(1) ESG incorporated into externalmanager selection(2) ESG not incorporated into externalmanager selection(B) Listed equity – active◉○(D) Fixed income – active◉○(E) Private equity◉○(F) Real estate◉○(G) Infrastructure◉○(H) Hedge funds

◉

○

22

External manager appointment
Indicator

Type ofindicator

Dependent on

Gateway toDisclosure

Subsection

PRI
Principle

OO 12

CORE

Multiple, seeguidance

Multiple, seeguidance

PUBLIC

External manager
appointment

1

For each externally managed asset class, select whether or not you incorporate ESG into external manager appointment. Your
response should refer to the appointment of the external managers who managed the relevant asset classes during the reporting
year, regardless of when their appointment took place.
(1) ESG incorporated into externalmanager appointment(2) ESG not incorporated into externalmanager appointment(B) Listed equity – active◉○(D) Fixed income – active◉○(E) Private equity◉○(F) Real estate◉○(G) Infrastructure◉○(H) Hedge funds

◉

○

23

External manager monitoring
Indicator

Type ofindicator

Dependent on

Gateway toDisclosure

Subsection

PRI
Principle

OO 13

CORE

Multiple, seeguidance

Multiple, seeguidance

PUBLIC

External manager
monitoring1

For each externally managed asset class, select whether or not you incorporated ESG into external manager monitoring during
the reporting year.
(1) ESG incorporated into externalmanager monitoring(2) ESG not incorporated into externalmanager monitoring(B) Listed equity – active◉○(D) Fixed income – active◉○(E) Private equity◉○(F) Real estate◉○(G) Infrastructure◉○(H) Hedge funds

◉

○

24

Voluntary reporting
Voluntary modules
Indicator

Type ofindicator

Dependent on

Gateway toDisclosure

Subsection

PRI
Principle

OO 14

CORE

Multiple, seeguidance

Multiple, seeguidance

PUBLIC

Voluntary
modules

GENERAL

The following modules are voluntary to report on in the separate PRI asset class modules as they account for less than 10% of
your total AUM and are under USD 10 billion. Please select if you wish to voluntarily report on the module.

(1) Yes, report on the module(2) No, opt out of reporting on themodule(A) Listed equity◉○(L) External manager selection,
appointment and monitoring(SAM) – private equity◉○(M) External manager selection,
appointment and monitoring(SAM) – real estate◉○(N) External manager selection,
appointment and monitoring(SAM) – infrastructure◉○(O) External manager selection,
appointment and monitoring(SAM) – hedge funds◉○

The following modules are mandatory to report on as they account for 10% or more of your total AUM or are over USD 10
billion. The ISP (Investment and Stewardship Policy) module is always applicable for reporting.
(1) Yes, report on the module
ISP: Investment and Stewardship
Policy◉25

(J) External manager selection,
appointment and monitoring(SAM) – listed equity◉(K) External manager selection,
appointment and monitoring(SAM) – ﬁxed income◉

ESG/sustainability funds and products
Labelling and marketing
Indicator

Type ofindicator

Dependent on

Gateway toDisclosure

Subsection

PRI
Principle

OO 16

CORE

Multiple, seeguidance

Multiple, seeguidance

PUBLIC

Labelling andmarketing

GENERAL

What percentage of your assets under management in each asset class are ESG/sustainability marketed funds or products,
and/or ESG/RI certiﬁed or labelled assets? Percentage ﬁgures can be rounded to the nearest 5% and should combine internallyand externally managed assets.
Percentage(B) Listed equity – active

0-25%(D) Fixed income – active

0.0%(E) Private equity

0.0%(F) Real estate

0.0%(G) Infrastructure

0.0%(H) Hedge funds

0.0%

26

IndicatorType of indicator

Dependent on

Gateway toDisclosure

Subsection

PRI Principle

OO 16.1

CORE

OO 16

ISP 52

PUBLIC

Labelling and marketing

GENERAL

What percentage of your total assets (per asset class) carry a formal ESG/RI certiﬁcation or label? Percentage ﬁgures can berounded to the nearest 5%.
Coverage of ESG/RI certiﬁcation or label:(A) Listed equity

0-25%

Climate investments
Asset breakdown
Indicator

Type of indicator

Dependent on

Gateway toDisclosure

Subsection

PRI Principle

OO 17

CORE

N/A

N/A

PUBLIC

Asset breakdown

GENERAL

What percentage of your assets under management is in targeted low-carbon or climate-resilient investments?
0-25%

27

Other asset breakdowns
Geographical breakdown
Indicator

Type ofindicator

Dependent on

GatewaytoDisclosure

Subsection

PRI
Principle

OO 18

CORE

Multiple, seeguidance

N/A

PUBLIC

Geographicalbreakdown

GENERAL

What is the geographical breakdown of your organisation's assets under management by investment destination (i.e. where theinvestments are located)?

(1) Listed
equity(2) Fixed
income –SSA(3) Fixed
income –corporate(4) Fixed
income –securitised(5) Fixed
income –private debt(A) Developed

>75%

>75%

>75%

>75%

>75%

(B) Emerging

0-25%

0-25%

0-25%

0-25%

0.0%

(C) Frontier

0.0%

0.0%

0.0%

0.0%

0.0%

(D) Other

0.0%

0.0%

0.0%

0.0%

0.0%

(6) Private
equity(7) Real estate(8)
Infrastructure(9) Hedge funds(A) Developed

>75%

>75%

>75%

>75%

(B) Emerging

0.0%

0.0%

0.0%

0.0%

(C) Frontier

0.0%

0.0%

0.0%

0.0%

(D) Other

0.0%

0.0%

0.0%

0.0%

28

Management by PRI signatories
Indicator

Type ofindicator

DependentonGatewaytoDisclosure

Subsection

PRI
Principle

OO 19

CORE

OO 5

N/A

PUBLICManagement by PRI
signatories

GENERAL

What approximate percentage (+/-5%) of your externally managed assets are managed by PRI signatories?
>75%

Fixed income constraints
Indicator

Type of indicator

Dependent on

Gateway toDisclosure

Subsection

PRI Principle

OO 20

CORE

OO 5.2 FI

OO 20.1

PUBLIC

Fixed income constraints

GENERAL

What percentage of your ﬁxed income assets are sub ject to constraints? The constraints may be regulatory requirements, credit
quality restrictions, currency constraints or similar.
Internal and external ﬁxed income assets sub ject to constraints(A) Fixed income – SSA>75%(B) Fixed income – corporate>75%(C) Fixed income – securitised>75%(D) Fixed income – private debt

>75%

29

Context and explanation
ESG not incorporated
Indicator

Type ofindicator

Dependent on

GatewaytoDisclosure

Subsection

PRI
Principle

OO 35

CORE

Multiple, seeguidance

N/A

PUBLICESG not
incorporated

1, 2

Describe why you currently do not incorporate ESG into your assets and/or why you currently do not conduct stewardship.
Description(C) Internally managed: Fixed income – SSA

Our internally managed FI strategies are passive. Passive
products are designed speciﬁcally to track targeted indices.
Our active ownership practices are currently focused on ourlisted equity assets.

(D) Internally managed: Fixed income – corporate

Our internally managed FI strategies are systematic andpassive. The systematic strategies we employ include credit,
region, duration and liquidity status for security selection.
Passive products are designed speciﬁcally to track targetedindices. Our active ownership practices are currently focusedon our listed equity assets.

(M) Internally managed: Other

Our internally managed "other" strategies are systematic andpassive. The systematic strategies we employ include currency,
cash and other alternatives. Our active ownership practices
are currently focused on our listed equity assets.

30

(Q) Externally managed: Fixed income – active

ESG issues are incorporated into our research through ourinvestment manager evaluation process, where the ESG
information is considered a key driver of our ranks, alongside
portfolio construction, research, risk management,
organizational structure and staﬃng. The potential for ESG
issues to impact opportunities and risks of manager strategies
is at the heart of our approach. Through a combination of
investment manager interviews, survey responses, andquantitative analysis of manager portfolios, Russell
Investments' analysts determine whether the manager
appropriately assesses the risk and return impacts of ESG
issues. ESG is formally incorporated into our investment
manager evaluation process through rankings of separate
ESG categories assessing both the quality and competitiveedge of a manager’s ESG investment skills. (response
continued in row below)
The ESG rank is considered in our subadvisor selection
process and is highlighted in our governance of funds. In
addition to reviewing ESG in selecting subadvisors, we
continually review Sustainability Risks in our funds with thesupport of our subadvisors and internal reporting, whilealigning our evaluation of Sustainability Risks with a varietyof themes, including the themes we support in our active
ownership practices. Our active ownership practices are
currently applied in our listed equity assets..

(R) Externally managed: Private equity

ESG issues are incorporated into our research through ourinvestment manager evaluation process, where the ESG
information is considered a key driver of our ranks, alongside
portfolio construction, research, risk management,
organizational structure and staﬃng. The potential for ESG
issues to impact opportunities and risks of manager strategies
is at the heart of our approach. Through a combination of
investment manager interviews, survey responses, andquantitative analysis of manager portfolios, Russell
Investments' analysts determine whether the manager
appropriately assesses the risk and return impacts of ESG
issues. ESG is formally incorporated into our investment
manager evaluation process through rankings of separate
ESG categories assessing both the quality and competitiveedge of a manager’s ESG investment skills. (response
continued in row below)

31

The ESG rank is considered in our subadvisor selection
process and is highlighted in our governance of funds. In
addition to reviewing ESG in selecting subadvisors, we
continually review Sustainability Risks in our funds with thesupport of our subadvisors and internal reporting, whilealigning our evaluation of Sustainability Risks with a varietyof themes, including the themes we support in our active
ownership practices. Our active ownership practices are
currently applied in our listed equity assets..

(S) Externally managed: Real estate

ESG issues are incorporated into our research through ourinvestment manager evaluation process, where the ESG
information is considered a key driver of our ranks, alongside
portfolio construction, research, risk management,
organizational structure and staﬃng. The potential for ESG
issues to impact opportunities and risks of manager strategies
is at the heart of our approach. Through a combination of
investment manager interviews, survey responses, andquantitative analysis of manager portfolios, Russell
Investments' analysts determine whether the manager
appropriately assesses the risk and return impacts of ESG
issues. ESG is formally incorporated into our investment
manager evaluation process through rankings of separate
ESG categories assessing both the quality and competitiveedge of a manager’s ESG investment skills. (response
continued in row below)
The ESG rank is considered in our subadvisor selection
process and is highlighted in our governance of funds. In
addition to reviewing ESG in selecting subadvisors, we
continually review Sustainability Risks in our funds with thesupport of our subadvisors and internal reporting, whilealigning our evaluation of Sustainability Risks with a varietyof themes, including the themes we support in our active
ownership practices. Our active ownership practices are
currently applied in our listed equity assets..

32

(T) Externally managed: Infrastructure

ESG issues are incorporated into our research through ourinvestment manager evaluation process, where the ESG
information is considered a key driver of our ranks, alongside
portfolio construction, research, risk management,
organizational structure and staﬃng. The potential for ESG
issues to impact opportunities and risks of manager strategies
is at the heart of our approach. Through a combination of
investment manager interviews, survey responses, andquantitative analysis of manager portfolios, Russell
Investments' analysts determine whether the manager
appropriately assesses the risk and return impacts of ESG
issues. ESG is formally incorporated into our investment
manager evaluation process through rankings of separate
ESG categories assessing both the quality and competitiveedge of a manager’s ESG investment skills. (response
continued in row below)
The ESG rank is considered in our subadvisor selection
process and is highlighted in our governance of funds. In
addition to reviewing ESG in selecting subadvisors, we
continually review Sustainability Risks in our funds with thesupport of our subadvisors and internal reporting, whilealigning our evaluation of Sustainability Risks with a varietyof themes, including the themes we support in our active
ownership practices. Our active ownership practices are
currently applied in our listed equity assets..

(U) Externally managed: Hedge funds

ESG issues are incorporated into our research through ourinvestment manager evaluation process, where the ESG
information is considered a key driver of our ranks, alongside
portfolio construction, research, risk management,
organizational structure and staﬃng. The potential for ESG
issues to impact opportunities and risks of manager strategies
is at the heart of our approach. Through a combination of
investment manager interviews, survey responses, andquantitative analysis of manager portfolios, Russell
Investments' analysts determine whether the manager
appropriately assesses the risk and return impacts of ESG
issues. ESG is formally incorporated into our investment
manager evaluation process through rankings of separate
ESG categories assessing both the quality and competitiveedge of a manager’s ESG investment skills. (response
continued in row below)

33

The ESG rank is considered in our subadvisor selection
process and is highlighted in our governance of funds. In
addition to reviewing ESG in selecting subadvisors, we
continually review Sustainability Risks in our funds with thesupport of our subadvisors and internal reporting, whilealigning our evaluation of Sustainability Risks with a varietyof themes, including the themes we support in our active
ownership practices. Our active ownership practices are
currently applied in our listed equity assets..

Investment and Stewardship Policy (ISP)
Responsible investment policy & governance
Responsible investment policy
Indicator

Type ofindicator

DependentonGateway toDisclosure

Subsection

PRI
Principle

ISP 1

CORE

N/A

ISP 1.1, ISP
1.2

PUBLIC

Responsible investment
policy1

Does your organisation have a formal policy or policies covering your approach to responsible investment? Your approach toresponsible investment may be set out in a standalone guideline, covered in multiple standalone guidelines or be part of a broader
investment policy. Your policy may cover various responsible investment elements such as stewardship, ESG guidelines,
sustainability outcomes, speciﬁc climate-related guidelines, RI governance and similar.
◉ (A) Yes, we do have a policy covering our approach to responsible investment○ (B) No, we do not have a policy covering our approach to responsible investment

34

IndicatorType ofindicator

DependentonGateway toDisclosure

Subsection

PRI
Principle

ISP 1.1

CORE

ISP 1

Multiple, seeguidance

PUBLIC

Responsible investment
policy1What elements does your responsible investment policy cover? The responsible investment elements may be set out in one or
multiple standalone guidelines, or they may be part of a broader investment policy.
☑ (A) Overall approach to responsible investment☐ (B) Guidelines on environmental factors☐ (C) Guidelines on social factors☐ (D) Guidelines on governance factors☑ (E) Approach to stewardship☑ (F) Approach to sustainability outcomes☑ (G) Approach to exclusions☐ (H) Asset class-speciﬁc guidelines that describe how ESG incorporation is implemented☑ (I) Deﬁnition of responsible investment and how it relates to our ﬁduciary duty
☑ (J) Deﬁnition of responsible investment and how it relates to our investment ob jectives☑ (K) Responsible investment governance structure☑ (L) Internal reporting and veriﬁcation related to responsible investment☑ (M) External reporting related to responsible investment☐ (N) Managing conﬂicts of interest related to responsible investment☐ (O) Other responsible investment aspects not listed here, please specify:
Indicator

Type ofindicator

DependentonGatewaytoDisclosure

Subsection

PRI
Principle

ISP 1.2

PLUS

ISP 1

N/A

PUBLIC

Responsible investment
policy1What mechanisms do you have in place to ensure that your policies are implemented in an aligned and consistent way across theorganisation?
Russell Investments has a robust governance structure with appropriate lines of segregation. Speciﬁcally we have global policies andprocedures set at the highest levels within the organization along with robust governance tools and processes to ensure adherence, andthe ability to ensure they are appropriately applied in every region and every asset class.
The Global Risk Management Committee (GRMC) and Internal Audit Committee are the two main groups responsible for the ﬁrm’s
internal control structure, and both report to the Executive Committee and the Board of Directors. The GRMC oversees Russell
Investments’ risk management program and reports regularly to the Internal Audit Committee. Together, they work to establish ouroverall risk vision, risk management framework and risk management objectives. The GRMC comprises senior oﬃcers who meetquarterly to review and evaluate material risks inherent in our business lines.

35

The Internal Audit team conducts structured reviews of key processes and risks, including detailed testing of mitigating controls. Russell
Investments has built the entire investment process over ﬁve decades to ensure effective execution of the investment management
process. The investment division is organized to design, construct and manage portfolios speciﬁc to client needs.
The investment division is governed by the Investment Strategy Committee (ISC). The ISC is authorized by the Executive Committee
and has the responsibility for the oversight of investment-related activities at Russell Investments, as well as reviewing investment
performance and establishing investment policy and strategy. Its members include the Global Chief Investment Oﬃcer, who serves as the
Chairperson, and senior investment division and risk professionals. The ISC delegates to numerous subcommittees to review andrecommend proposals to create new investment products, new fund launches and hire/terminate investment managers.
The groups reporting to the ISC have written charters outlining their oversight obligations, as well as many groups having annual
objectives. Our governance process features performance measurement with much attention given to metrics that reﬂect the outcomes
our clients seek and ensure accountability. We review these metrics and outcomes with the accountable parties on a regular cycle andcontinually revisit mandates, objectives and performance metrics to conﬁrm their alignment with the mission of each group. Each group
has documentation practices outlined in the charter to record approvals, decisions, and oversight activities. We favour an integrated
approach to responsible investing and have several ESG experts embedded throughout our organization.
The Global Responsible Investing Steering Group consists of representatives from various business units such as solutions, client-facing,marketing, the investment division and compliance and legal. The purpose of this group is to facilitate and maintain the ability ofRussell Investments to provide a world-class and harmonized approach to responsible investing solutions and sustainability, with a clear
focus on creating investment value. This global group has two executive-level sponsors, the Global Chief Investment Oﬃcer and Headof EMEA. This group is chaired by the Head of Responsible Investing.
In addition to the steering group, we have multiple responsible investing related working groups tasked with the speciﬁc delivery of
research (including climate-related), strategy development and compliance with the fast-changing regulatory landscape. These working
groups include the Global Regulatory Steering Committee, Investment Division Responsible Investing Council, ESG Marketing
Taskforce and Corporate Social Responsibility. The ID Responsible Investing Council, which reports to the ISC, guides the Investment
Division’s initiatives related to responsible investing. The Proxy Voting & Engagement Committee establishes and oversees our proxyvoting policies, procedures, guidelines and voting decisions, and reports directly to the Global Chief Investment Oﬃcer.

Indicator

Type ofindicator

DependentonGatewaytoDisclosure

Subsection

PRI
Principle

ISP 2

CORE

ISP 1.1

N/A

PUBLIC

Responsible investment
policy6

Indicate which of your responsible investment policy elements are publicly available and provide links.
☑ (A) Overall approach to responsible investment. Add link(s):“Best practices for responsible investing”: https://russellinvestments.com/-/media/ﬁles/us/insights/institutions/non-proﬁt/best-practicesfor-responsible-investing-executive-summary.pdf?la=en&hash=AF035A7366078F702F21CEF214B6193CCB194AB1☐ (E) Approach to stewardship. Add link(s):☐ (F) Approach to sustainability outcomes. Add link(s):☐ (G) Approach to exclusions. Add link(s):☐ (I) Deﬁnition of responsible investment and how it relates to our ﬁduciary duty. Add link(s):☐ (J) Deﬁnition of responsible investment and how it relates to our investment ob jectives. Add link(s):☐ (K) Responsible investment governance structure. Add link(s):☐ (L) Internal reporting and veriﬁcation related to responsible investment. Add link(s):☐ (M) External reporting related to responsible investment. Add link(s):36☐ (P) Our responsible investment policy elements are not publicly available
Indicator

Type ofindicator

DependentonGatewaytoDisclosure

Subsection

PRI
Principle

ISP 3

CORE

ISP 1.1

N/A

PUBLIC

Responsible investment
policy1What percentage of your total assets under management are covered by your policy elements on overall approach to responsible
investment and/or guidelines on environmental, social and governance factors?
○ (A) Overall approach to responsible investment
AUM coverage of all policy elements in total:>75%

Indicator

Type ofindicator

DependentonGatewaytoDisclosure

Subsection

PRI
Principle

ISP 4

CORE

ISP 1.1

N/A

PUBLIC

Responsible investment
policy1

Which elements does your exclusion policy include?
☑ (A) Legally required exclusions (e.g. those required by domestic/international law, bans, treaties or embargoes)☐ (B) Exclusions based on our organisation's values or beliefs (e.g. regarding weapons, alcohol, tobacco and/or avoiding otherparticular sectors, products, services or regions)☑ (C) Exclusions based on screening against minimum standards of business practice based on international norms (e.g. OECD
guidelines, the UN Human Rights Declaration, Security Council sanctions or the UN Global Compact)

37

GovernanceIndicator

Type of indicator

Dependent on

Gateway toDisclosure

Subsection

PRI Principle

ISP 6

CORE

N/A

ISP 8

PUBLIC

Governance1

Do your organisation's board, chief-level staff, investment committee and/or head of department have formal oversight andaccountability for responsible investment?
☐ (A) Board and/or trustees☑ (B) Chief-level staff (e.g. Chief Executive Oﬃcer (CEO), Chief Investment Oﬃcer (CIO) or Chief Operating Oﬃcer (COO))☑ (C) Investment committee☑ (D) Other chief-level staff, please specify:
Head of EMEA

☑ (E) Head of department, please specify department:
Head of Research, Head of Portfolio Management☐ (F) None of the above roles have oversight and accountability for responsible investment
Indicator

Type of indicator

Dependent on

Gateway toDisclosure

Subsection

PRI Principle

ISP 7

CORE

N/A

ISP 8

PUBLIC

Governance1

In your organisation, which internal or external roles have responsibility for implementing responsible investment?
☐ (A) Board and/or trustees☑ (B) Chief-level staff (e.g. Chief Executive Oﬃcer (CEO), Chief Investment Oﬃcer (CIO) or Chief Operating Oﬃcer (COO))☑ (C) Investment committee☑ (D) Other chief-level staff [as speciﬁed]☑ (E) Head of department [as speciﬁed]☑ (F) Portfolio managers☑ (G) Investment analysts☑ (H) Dedicated responsible investment staff☐ (I) Investor relations☑ (J) External managers or service providers☑ (K) Other role, please specify:
Proxy voting partner, Glass Lewis☐ (L) Other role, please specify:☐ (M) We do not have roles with responsibility for implementing responsible investment.

38

People and capabilities
Indicator

Type ofindicator

DependentonGateway toDisclosure

Subsection

PRI Principle

ISP 8

CORE

ISP 6, ISP 7

ISP 8.1, ISP 8.2

PUBLIC

People and capabilities

GeneralWhat formal ob jectives for responsible investment do the roles in your organisation have?

(2) Chieflevel staff(3)
Investmentcommittee(4) Otherchief-levelstaff [asspeciﬁed](5) Head of
department[as speciﬁed](6) Portfolio
managers(A) Ob jective for ESG
incorporation in investment
activities

☑

☑

☐

☑

☑

(B) Ob jective for contributing to
the development of theorganisation's ESG incorporation
approach

☑

☑

☑

☑

☑

(C) Ob jective for contributing tothe organisation's stewardship
activities (e.g. through sharing
ﬁndings from continuous ESG
research or investment decisions)

☑

☐

☐

☑

☑

(D) Ob jective for ESG performance

☑

☐

☐

☑

☑

(E) Other ob jective related toresponsible investment [as speciﬁed]

☐

☐

☑

☐

☑

(F) Other ob jective related toresponsible investment [as speciﬁed]

☐

☐

☐

☐

☐

(G) No formal ob jectives forresponsible investment exist for this
role

☐

☐

☐

☐

☐

39

(7) Investment
analysts(8) Dedicatedresponsible
investment staff(10) Externalmanagers orservice providers(11) Other role(A) Ob jective for ESG incorporation
in investment activities

☑

☑

☐

☐

(B) Ob jective for contributing to
the development of theorganisation's ESG incorporation
approach

☑

☑

☐

☐

(C) Ob jective for contributing tothe organisation's stewardship
activities (e.g. through sharing
ﬁndings from continuous ESG
research or investment decisions)

☑

☑

☑

☑

(D) Ob jective for ESG performance

☑

☑

☑

☐

(E) Other ob jective related toresponsible investment [as speciﬁed]

☐

☑

☐

☐

(F) Other ob jective related toresponsible investment [as speciﬁed]

☑

☐

☐

☐

(G) No formal ob jectives forresponsible investment exist for this
role

☐

☐

☐

☐

Please specify for "(E) Other ob jective related to responsible investment".
Bringing ESG-related products to market.

Please specify for "(F) Other ob jective related to responsible investment".
Developing in-house climate change risk reporting, research and modeling.

40

IndicatorType of indicator

Dependent on

Gateway toDisclosure

Subsection

PRI Principle

ISP 8.1

PLUS

ISP 8

N/A

PUBLIC

People and capabilities

GeneralDescribe the key responsible investment performance indicators (KPIs) or benchmarks that your organisation uses to compare
and assess the performance of your professionals in relation to their responsible investment ob jectives.
Russell Investments utilizes several KPIs to compare and assess the performance of our investment professionals in relation to their
responsible investment objectives. Manager research analysts are assessed on the coverage and quality of the ESG dis-aggregated rank.
The ESG dis-aggregated rank is a top-tier contributor to the overall rank of all members of our active product universes. Portfolio
managers are assessed on their participation in ESG training, their consideration of ESG as part of their subadvisor selection andoversight, their ability to evidence the inclusion of Sustainability Risks in their strategies, and their participation in shareholder
engagement activities. Quantitative research analysts focused on ESG topics are assessed on the quality of their research and content
created on ESG-related topics including strategy development, metrics development and the assessment of climate change risk. All ofthese investment professionals have ESG-related objectives clearly articulated in their goals. As well, multiple investment professionals
across the Investment Division are members of our Proxy and Engagement Committee--as part of this committee, these investment
professionals have KPIs related to the quantity and quality of our engagements. Certain Russell Investments sales and client-service
associates have AUM goals for ESG-related products, are required to attend ESG training, and are tasked with working with theirclients on their ESG-related goals.

Indicator

Type of indicator

Dependent on

Gateway toDisclosure

Subsection

PRI Principle

ISP 8.2

CORE

ISP 8

N/A

PUBLIC

People and capabilities

GeneralWhich responsible investment ob jectives are linked to variable compensation for roles in your organisation?

41

RI ob jectives linked to variable compensation forroles in your organisation:(2) Chief-level staff (e.g. Chief Executive Oﬃcer (CEO), Chief Investment Oﬃcer (CIO) or Chief Operating Oﬃcer (COO))(A) Ob jective for ESG incorporation in investment activities☑

(B) Ob jective for contributing to the development of the organisation's
ESG incorporation approach☑

(C) Ob jective for contributing to the organisation's stewardship activities(e.g. through sharing ﬁndings from continuous ESG research orinvestment decisions)☑

(D) Ob jective for ESG performance☑

(3) Investment committee(A) Ob jective for ESG incorporation in investment activities☑

(B) Ob jective for contributing to the development of the organisation's
ESG incorporation approach☑

(4) Other chief-level staff(B) Ob jective for contributing to the development of the organisation's
ESG incorporation approach☑

(E) Other ob jective related to responsible investment (as speciﬁed in ISP 8
option E)☑

42(5) Head of department(A) Ob jective for ESG incorporation in investment activities☑

(B) Ob jective for contributing to the development of the organisation's
ESG incorporation approach☑

(C) Ob jective for contributing to the organisation's stewardship activities(e.g. through sharing ﬁndings from continuous ESG research orinvestment decisions)☑

(D) Ob jective for ESG performance☑

(6) Portfolio managers(A) Ob jective on ESG incorporation in investment activities☑

(B) Ob jective for contributing to the development of the organisation's
ESG incorporation approach☑

(C) Ob jective for contributing to the organisation's stewardship activities(e.g. through sharing ﬁndings from continuous ESG research orinvestment decisions)☑

(D) Ob jective for ESG performance☑

(E) Other ob jective related to responsible investment (as speciﬁed in ISP 8
option E)☑

43(7) Investment analysts(A) Ob jective for ESG incorporation in investment activities☑

(B) Ob jective for contributing to the development of the organisation's
ESG incorporation approach☑

(C) Ob jective for contributing to the organisation's stewardship activities(e.g. through sharing ﬁndings from continuous ESG research orinvestment decisions)☑

(D) Ob jective for ESG performance☑

(F) Other ob jective related to responsible investment (as speciﬁed in ISP 8
option F)☑

(8) Dedicated responsible investment staff(A) Ob jective for ESG incorporation in investment activities☑

(B) Ob jective for contributing to the development of the organisation's
ESG incorporation approach☑

(C) Ob jective for contributing to the organisation's stewardship activities(e.g. through sharing ﬁndings from continuous ESG research orinvestment decisions)☑

(D) Ob jective for ESG performance☑

(E) Other ob jective related to responsible investment (as speciﬁed in ISP 8
option E)☑

(10) External managers or service providers(C) Ob jective for contributing to the organisation's stewardship activities(e.g. through sharing ﬁndings from continuous ESG research orinvestment decisions)☑

(D) Ob jective for ESG performance☑

44

(11) Other role(C) Ob jective for contributing to the organisation's stewardship activities(e.g. through sharing ﬁndings from continuous ESG research orinvestment decisions)☑

(G) We have not linked any RI ob jectives to variable compensation☐

Indicator

Type of indicator

Dependent on

Gateway toDisclosure

Subsection

PRI Principle

ISP 9

CORE

N/A

N/A

PUBLIC

People and capabilities

GeneralHow frequently does your organisation assess the responsible investment capabilities and training needs among your investment
professionals?
○ (A) Quarterly or more frequently◉ (B) Bi-annually○ (C) Annually○ (D) Less frequently than annually○ (E) On an ad hoc basis○ (F) We do not have a process for assessing the responsible investment capabilities and training needs among our investment
professionals

Strategic asset allocation
Indicator

Type of indicator

Dependent on

Gateway toDisclosure

Subsection

PRI Principle

ISP 10CORE

N/A

ISP 10.1

PUBLIC

Strategic asset allocation

1

Does your organisation incorporate ESG factors into your strategic asset allocation?
☐ (A) We incorporate ESG factors into calculations for expected risks and returns of asset classes☐ (B) We speciﬁcally incorporate physical, transition and regulatory changes related to climate change into calculations for
expected risks and returns of asset classes☑ (C) No, we do not incorporate ESG considerations into our strategic asset allocation☐ (D) Not applicable, we do not have a strategic asset allocation process

45

Stewardship
Stewardship policy
Indicator

Type ofindicator

Dependent on

Gateway toDisclosure

Subsection

PRI Principle

ISP 11

CORE

Multiple, seeguidance

N/A

PUBLIC

Stewardship policy

2

What percentage of your assets under management does your stewardship policy cover?

(A) Listed equity>75%

Indicator

Type of indicator

Dependent on

Gateway toDisclosure

Subsection

PRI Principle

ISP 12CORE

ISP 1.1

ISP 12.1

PUBLIC

Stewardship policy

2Which elements does your organisation's stewardship policy cover? The policy may be a standalone guideline or part of a wider
RI policy.
☑ (A) Key stewardship ob jectives☑ (B) Prioritisation approach of ESG factors and their link to engagement issues and targets☐ (C) Prioritisation approach depending on entity (e.g. company or government)☑ (D) Speciﬁc approach to climate-related risks and opportunities☐ (E) Stewardship tool usage across the organisation, including which, if any, tools are out of scope and when and how different
tools are used and by whom (e.g. specialist teams, investment teams, service providers, external investment managers or similar)☐ (F) Stewardship tool usage for speciﬁc internal teams (e.g. specialist teams, investment teams or similar)☐ (G) Stewardship tool usage for speciﬁc external teams (e.g. service providers, external investment managers or similar)☑ (H) Approach to collaboration on stewardship☑ (I) Escalation strategies☑ (J) Conﬂicts of interest☐ (K) Details on how the stewardship policy is implemented and which elements are mandatory, including how and when thepolicy can be overruled☐ (L) How stewardship efforts and results should be communicated across the organisation to feed into investment decisionmaking and vice versa☐ (M) None of the above elements are captured in our stewardship policy

46

IndicatorType of indicator

Dependent on

Gateway toDisclosure

Subsection

PRI Principle

ISP 12.1

PLUS

ISP 12

N/A

PUBLIC

Stewardship policy2

Describe any additional details related to your stewardship policy elements or your overall stewardship approach.
As part of our global practice, we manage and implement our stewardship practice in alignment with policies regarding Investment
Philosophy, Responsible Investing, Sustainability Risks, Proxy Voting Guidelines, Engagement Practices, corporate values and industry
initiatives. To undertake management and governance we utilize a variety of external and internal data tools and analytics.

Stewardship policy implementation
Indicator

Type ofindicator

DependentonGatewaytoDisclosure

Subsection

PRI
Principle

ISP 13CORE

ISP 1.1

N/A

PUBLIC

Stewardship policy
implementation2

How is your stewardship policy primarily applied?
◉ (A) It requires our organisation to take certain actions○ (B) It describes default actions that can be overridden (e.g. by investment teams for certain portfolios)○ (C) It creates permission for taking certain measures that are otherwise exceptional○ (D) We have not developed a uniform approach to applying our stewardship policy
Indicator

Type ofindicator

Dependent on

GatewaytoDisclosure

Subsection

PRI
Principle

ISP 14

PLUS

Multiple, seeguidance

N/A

PUBLIC

Stewardship policy
implementation2

How does your organisation ensure that its stewardship policy is implemented by external service providers? Please provide
examples of the measures your organisation takes when selecting external providers, when designing engagement mandates andwhen monitoring the activities of external service providers.
Provide examples below:

47

(A) Measures taken when selecting external providers:

We conduct an annual service review that includes statistics
showing the previous year’s vote activity, accuracy andtimeliness provided by Glass Lewis’ research team. Russell
Investments has partnered with Sustainalytics as anengagement service provider because their model allows for
close oversight and integration with our internal active
ownership and investment processes. We re-evaluate theengagement at the end of each contract term, typically three
years.

(B) Measures taken when designing engagement mandates forexternal providers:

When selecting or endorsing engagement activity facilitatedby our service partner, Sustainalytics, we maximize thefollowing: a) alignment with our ESG focus areas, b)
potential to positively affect investment risk/reward, c) fundexposure, and d) geographic breadth(C) Measures taken to monitor external providers' alignment
with our organisation's stewardship policy:

Glass Lewis is responsible for applying our custom voting
guidelines; these are reviewed and updated at least annually
by our Guideline Subcommittee, to ensure that our voting
activities are aligned with current best practices.
Our Engagement Subcommittee communicates regularly with
Sustainalytics on the positioning of engagement themes,
target company selection, and on progress and outcomes.
Investment professionals regularly participate in engagement
alongside Sustainalytics.

Stewardship objectives
Indicator

Type ofindicator

Dependent on

GatewaytoDisclosure

Subsection

PRI
Principle

ISP 15

CORE

Multiple, seeguidance

N/A

PUBLIC

Stewardshipob jectives

2

For the majority of assets within each asset class, which of the following best describes your primary stewardship ob jective?
(1) Listed equity(A) Maximise the risk–return
proﬁle of individual investments○(B) Maximise overall returns acrossthe portfolio○

48

(C) Maximise overall value tobeneﬁciaries/clients◉(D) Contribute to shaping speciﬁcsustainability outcomes (i.e. deliver
impact)○Stewardship prioritisation
Indicator

Type ofindicator

Dependent on

GatewaytoDisclosure

Subsection

PRI
Principle

ISP 16

CORE

Multiple, seeguidance

N/A

PUBLIC

Stewardshipprioritisation

2

What key criteria does your organisation use to prioritise your engagement targets? For asset classes such as real estate, private
equity and infrastructure, you may consider this as key criteria to prioritise actions taken on ESG factors for assets, portfolio
companies and/or properties in your portfolio. Select up to 3 options per asset class from the list.
(1) Listed equity(A) The size of our holdings in theentity or the size of the asset,
portfolio company and/or property☑

(B) The materiality of ESG factors
on ﬁnancial and/or operational
performance☑

(C) Speciﬁc ESG factors withsystemic inﬂuence (e.g. climate or
human rights)☑

(D) The ESG rating of the entity☐(E) The adequacy of public
disclosure on ESG
factors/performance☐(F) Speciﬁc ESG factors based on
input from clients☐49

(G) Speciﬁc ESG factors based on
input from beneﬁciaries☐(H) Other criteria to prioritise
engagement targets, please specify:☐(I) We do not prioritise ourengagement targets☐

Stewardship methods
Indicator

Type ofindicator

Dependent on

GatewaytoDisclosure

Subsection

PRI
Principle

ISP 17

PLUS

Multiple, seeguidance

N/A

PUBLIC

Stewardshipmethods2

Please rank the methods that are most important for your organisation in achieving its stewardship ob jectives. Ranking options:
1 = most important, 5 = least important.
(A) Internal resources (e.g. stewardship team, investment team, ESG team or staff )1(B) External investment managers, third-party operators and/or external property
managers (if applicable)

3(C) External paid services or initiatives other than investment managers, third-party
operators and/or external property managers (paid beyond a membership fee)2(D) Informal or unstructured collaborations with peers

5(E) Formal collaborative engagements (e.g. PRI-coordinated collaborative engagements,
Climate Action 100+, the Initiative Climat International (iCI) or similar)

450Collaborative stewardship
Indicator

Type ofindicator

Dependent on

GatewaytoDisclosure

Subsection

PRI
Principle

ISP 18

CORE

Multiple, seeguidance

ISP 18.1

PUBLIC

Collaborative
stewardship2

Which of the following best describes your organisation's default position, or the position of the service providers/externalmanagers acting on your behalf, with regards to collaborative stewardship efforts such as collaborative engagements?
◉ (A) We recognise that stewardship suffers from a collective action problem, and, as a result, we actively prefer collaborative
efforts○ (B) We collaborate when our individual stewardship efforts have been unsuccessful or are likely to be unsuccessful, i.e. as an
escalation tool
○ (C) We collaborate in situations where doing so would minimise resource cost to our organisation○ (D) We do not have a default position but collaborate on a case-by-case basis○ (E) We generally do not join collaborative stewardship efforts
Indicator

Type of indicator

Dependent on

Gateway toDisclosure

Subsection

PRI Principle

ISP 18.1

PLUS

ISP 18N/A

PUBLIC

Collaborative stewardship2

Describe your position on collaborating for stewardship.
In 2020 Russell Investments began a partnership with Sustainalytics for collaborative engagements. Sustainalytics’ thematic engagement
programs are designed to extend over a three-year period, allowing Russell Investments and other participants to build relationships
with a selected set of issuers, to encourage development in the thematic channel to which they belong. In addition to Sustainalytics,
Russell Investments joined Climate Action 100+ in early 2020. ClimateAction 100+ is an investor initiative launched in 2017 to ensure
the world's largest corporate greenhouse gas emitters take necessary action on climate change. With ClimateAction 100+ we havedirectly engaged with a select number of companies on climate transition through the regional entities. Lastly, also in 2020, where ourpriorities intersect, we have begun collaborating with our subadvisor partners in our direct-to-company engagement activity.

51

Escalation strategies
Indicator

Type ofindicator

Dependent on

GatewaytoDisclosure

Subsection

PRI
Principle

ISP 19PLUS

Multiple, seeguidance

N/A

PUBLIC

Escalation
strategies

2

Which of these measures did your organisation, or the service providers/external managers acting on your behalf, use mostfrequently when escalating initial stewardship approaches that were deemed unsuccessful?
(1) Listed equity(A) Collaboratively engaging theentity with other investors☑

(B) Filing/co-ﬁling/submitting ashareholder resolution or proposal☐(C) Publicly engaging the entity(e.g. open letter)☐(D) Voting against the re-election of
one or more board directors☑

(E) Voting against the chair of theboard of directors☐(F) Voting against the annual
ﬁnancial report☑

(G) Divesting or implementing anexit strategy☐(H) We did not use any escalation
measures during the reporting year.
Please explain why below☐

52

IndicatorType ofindicator

Dependent on

GatewaytoDisclosure

Subsection

PRI
Principle

ISP 20

CORE

Multiple, seeguidance

N/A

PUBLIC

Escalation
strategies

2

If initial stewardship approaches were deemed unsuccessful, which of the following measures are excluded from the potential
escalation actions of your organisation or those of the service providers/external managers acting on your behalf ?
(1) Listed equity(A) Collaboratively engaging theentity with other investors☐(B) Filing/co-ﬁling/submitting ashareholder resolution or proposal☐(C) Publicly engaging the entity(e.g. open letter)☐(D) Voting against the re-election of
one or more board directors☐(E) Voting against the chair of theboard of directors☐(F) Voting against the annual
ﬁnancial report☐(G) Divesting or implementing anexit strategy☑

(H) We do not have any restrictions
on the escalation measures we can
use

☐

53

Alignment and effectivenessIndicator

Type ofindicator

Dependent on

GatewaytoDisclosure

Subsection

PRI
Principle

ISP 21

PLUS

Multiple, seeguidance

N/A

PUBLICAlignment andeffectiveness2

Describe how you coordinate stewardship across your organisation to ensure that stewardship progress and results feed into
investment decision-making and vice versa.
Russell Investments’ active ownership activities are directed by the Proxy Voting & Engagement Committee (PV&EC), a globally
diverse group of our investment professionals from manager research, portfolio management, quantitative and capital markets research,and portfolio implementation roles; however, many other investment professionals also contribute to our active ownership program.
Portfolio managers support Russell Investments’ ﬁduciary duties in this area through participation in individually led and collaborative
engagements and through oversight of the stewardship actions of our subadvisors communications. When appropriate, PM teams also
facilitate the collection of subadvisor input on high proﬁle or impactful proxies on an ad hoc basis and share Russell Investments voting
guidelines and voting intentions. Finally, when practical, Russell Investments’ portfolio managers conduct direct-to-company,
collaborative engagements together with subadvisors, who are a rich source of insight.

Stewardship examples
Indicator

Type ofindicator

Dependent on

GatewaytoDisclosure

Subsection

PRI
Principle

ISP 22

PLUS

Multiple, seeguidance

N/A

PUBLIC

Stewardshipexamples2

Describe stewardship activities that you participated in during the reporting year that led to desired changes in the entity you
interacted with. Include what ESG factor(s) you engaged on and whether your stewardship activities were primarily focused on
managing ESG risks and opportunities or delivering sustainability outcomes.
(1) Engagement type(2) Primary goal of stewardship activity(A) Example 1a) Internally (or service provider) leda) Managing ESG risks/opportunities(B) Example 2b) Collaborativec) Both managing ESG risks anddelivering outcomes(C) Example 3a) Internally (or service provider) leda) Managing ESG risks/opportunities

54

(A) Example 1(B) Example 2(3) The ESG factors you focused onin the stewardship activity(4) Description of stewardship activity
and the desired change(s) you achieved

Governance and executive
compensation

Discussion with a US-based datamanagement software company on
executive compensation following a voteagainst. Members of the Engagement
Subcommittee and a member of ourportfolio management team contacted
the company to follow up on previously
discussed concerns. While the company
explained that a one-off circumstancecreated extenuating circumstances,
Russell Investments reiterated that
until they had demonstrably done more
to align pay with their performance, wewould continue to vote against. The
company promised that pay andperformance would be better aligned in
the future. We will continue to monitor
the company for progress.

Climate change risks

Members of the portfolio management
team participated in a joint engagementwith a packaged-food company based inJapan led by our manager subadvisor.
Our portfolio management team joined
these discussions to support thesubadvisor’s messaging and make ourinterest in the topic known to thecompany. This engagement was afollow-up to a 2019 collaborative
engagement conversation on climatechange risks, and we found that as aresult of the prior year’s engagement,
the company had committed to the
TCFD reporting framework in June
2020.

55

The Engagement Subcommittee andlead portfolio manager initiated a multipronged discussion with a US packaging
company concerning sustainability
disclosures and diversity. When we
noted that the high number of longstanding board members could beconsidered entrenched, the company
expressed an intention to add fresh
perspective via upcoming openings. We
assessed their sustainability reporting asstrong overall but noted that some
important water usage metrics werelacking, and we encouraged further
disclosure of this data over time. We
intend to monitor further developments.

Sustainability disclosures anddiversity(C) Example 3

Engaging policymakers
Indicator

Type ofindicator

DependentonGateway toDisclosure

Subsection

PRI
Principle

ISP 23CORE

N/A

Multiple, seeguidance

PUBLICEngaging
policymakers

2

How does your organisation, or the external investment managers or service providers acting on your behalf, engage with
policymakers for a more sustainable ﬁnancial system?
☑ (A) We engage with policymakers directly☑ (B) We provide ﬁnancial support, are members of and/or are in another way aﬃliated with third-party organisations,
including trade associations and non-proﬁt organisations, that engage with policymakers☐ (C) We do not engage with policymakers directly or indirectly56IndicatorType of indicator

Dependent on

Gateway toDisclosure

Subsection

PRI Principle

ISP 23.1

CORE

ISP 23

N/A

PUBLICEngaging policymakers

2What methods do you, or the external investment managers or service providers acting on your behalf, use to engage with
policymakers for a more sustainable ﬁnancial system?
☐ (A) We participate in "sign-on" letters on ESG policy topics. Describe:☑ (B) We respond to policy consultations on ESG policy topics. Describe:

We engaged with ICI, SIFMA and CCIT as the US Department of Labor updated ERISA guidance on ESG and Proxy Voting guidance☐ (C) We provide technical input on ESG policy change. Describe:☐ (D) We proactively engage ﬁnancial regulators on ﬁnancial regulatory topics regarding ESG integration, stewardship,disclosure or similar. Describe:☐ (E) We proactively engage regulators and policymakers on other policy topics. Describe:☐ (F) Other methods used to engage with policymakers. Describe:
Indicator

Type of indicator

Dependent on

Gateway toDisclosure

Subsection

PRI Principle

ISP 23.2

CORE

ISP 23

N/A

PUBLICEngaging policymakers

2

Do you have governance processes in place (e.g. board accountability and oversight, regular monitoring and review ofrelationships) that ensure your policy activities, including those through third parties, are aligned with your position onsustainable ﬁnance and your commitment to the 6 Principles of the PRI?
○ (A) Yes, we have governance processes in place to ensure that our policy activities are aligned with our position on sustainableﬁnance and our commitment to the 6 Principles of the PRI. Describe your governance processes:◉ (B) No, we do not have these governance processes in place. Please explain why not:Russell Investments engages in policies that are aligned with our position on sustainable ﬁnance and our commitment to the 6 Principlesof the PRI. The oversight of these activities is currently informal and typically involves discussions and signoff by executive leadership,
however, we do not formally prescribe how we will assure that alignment. We regularly update and review our policies and areconsidering speciﬁc policies of this type.

57

Engaging policymakers – Policies
Indicator

Type ofindicator

DependentonGatewaytoDisclosure

Subsection

PRI
Principle

ISP 24CORE

ISP 23

ISP 24.1

PUBLICEngaging policymakers –Policies2

Do you have policies in place that ensure that your political inﬂuence as an organisation is aligned with your position onsustainable ﬁnance and your commitment to the 6 Principles of the PRI?
○ (A) Yes, we have a policy(ies) in place. Describe your policy(ies):◉ (B) No, we do not a policy(ies) in place. Please explain why not:Russell Investments inﬂuences policy to be aligned with our position on sustainable ﬁnance and our commitment to the 6 Principles of
the PRI. The oversight of these activities is currently informal and typically involves discussions and signoff by executive leadership,
however, we do not formally prescribe how we will assure that alignment. We regularly update and review our policies and areconsidering speciﬁc policies of this type.

Engaging policymakers – Transparency
Indicator

Type ofindicator

DependentonGatewaytoDisclosure

Subsection

PRI
Principle

ISP 25CORE

ISP 23

N/A

PUBLICEngaging policymakers –Transparency

2

During the reporting year, did your organisation publicly disclose your policy engagement activities or those conducted on yourbehalf by external investment managers/service providers?
☐ (A) We publicly disclosed details of our policy engagement activities. Add link(s):☐ (B) We publicly disclosed a list of our third-party memberships in or support for trade associations, think-tanks or similarthat conduct policy engagement activities with our support or endorsement. Add link(s):☑ (C) No, we did not publicly disclose our policy engagements activities during the reporting year. Explain why:
We regularly update and review our practices and are considering this type of disclosure.

☐ (D) Not applicable, we did not conduct policy engagement activities

58

Climate change
Public support
Indicator

Type of indicator

Dependent on

Gateway toDisclosure

Subsection

PRI Principle

ISP 26

CORE

N/A

N/A

PUBLIC

Public support

General

Does your organisation publicly support the Paris Agreement?
◉ (A) Yes, we publicly support the Paris Agreement Add link(s) to webpage or other public document/text expressing support
for the Paris Agreement:
https://russellinvestments.com/uk/about-us/newsroom/2021/russell-investments-announces-net-zero-carbon-emissions-goal○ (B) No, we currently do not publicly support the Paris Agreement
Indicator

Type of indicator

Dependent on

Gateway toDisclosure

Subsection

PRI Principle

ISP 27

CORE

N/A

N/A

PUBLIC

Public support

General

Does your organisation publicly support the Task Force on Climate-Related Financial Disclosures (TCFD)?
◉ (A) Yes, we publicly support the TCFD Add link(s) to webpage or other public document/text expressing support for the
TCFD:
https://russellinvestments.com/uk/about-us/responsible-investing○ (B) No, we currently do not publicly support the TCFD

59

GovernanceIndicator

Type of indicator

Dependent on

Gateway toDisclosure

Subsection

PRI Principle

ISP 28

CORE

N/A

N/A

PUBLIC

Governance

GeneralHow does the board or the equivalent function exercise oversight over climate-related risks and opportunities?
☑ (A) By establishing internal processes through which the board or the equivalent function are informed about climate-relatedrisks and opportunities. Specify:

The Russell Investments Global Responsible Investing Steering Group reports bi-annually to board members on all responsible investing
matters.

☐ (B) By articulating internal/external roles and responsibilities related to climate. Specify:☐ (C) By engaging with beneﬁciaries to understand how their preferences are evolving with regard to climate change. Specify:☑ (D) By incorporating climate change into investment beliefs and policies. Specify:

Russell Investments' policy is to research, measure, report and consider climate change risk and opportunities as integral parts of ourinvesting practice, our active ownership, and our business operations. Our measures, reported metrics, and consideration of climate risk
and opportunities are integrated into our sub-advisor research and selection, portfolio management, advice, proxy voting andshareholder engagement, and day-to-day business.

☐ (E) By monitoring progress on climate-related metrics and targets. Specify:☑ (F) By deﬁning the link between ﬁduciary duty and climate risks and opportunities. Specify:

Russell Investments’ policy is to integrate sustainability risks in our investment solutions by identifying, evaluating and managing
relevant risks in our investment manager review process, and portfolio management and through implementing proprietary solutions. We
believe sustainability risks are most relevant to investment outcomes when they exhibit ﬁnancial materiality, and, like all investment
risks, are incorporated by balancing expected risk with expected reward.
In managing investment solutions, we consider ﬁnancially-material sustainability risks in the context of expected rewards using a blendof inputs from sources including, but not limited to, investment managers, third-party data sources and Russell Investments propriety
analysis. Furthermore, we incorporate bespoke sustainability risks based on clients’ requirements for customized mandates. As well, weseek to collaborate with our advisory clients to consider, monitor and manage sustainability risk priorities in their portfolios.

☐ (G) Other measures to exercise oversight, please specify:☐ (H) The board or the equivalent function does not exercise oversight over climate-related risks and opportunities
Indicator

Type of indicator

Dependent on

Gateway toDisclosure

Subsection

PRI Principle

ISP 29

CORE

N/A

N/A

PUBLIC

Governance

GeneralWhat is the role of management in assessing and managing climate-related risks and opportunities?
☑ (A) Management is responsible for identifying climate-related risks/opportunities and reporting them back to the board or theequivalent function. Specify:
The Russell Investments Global Responsible Investing Steering Group includes the CIO and other Executive Committee members. The
Steering Group receives regular updates on our climate change research and reporting.

☑ (B) Management implements the agreed-upon risk management measures. Specify:

60

Russell Investments’ policy is to integrate sustainability risks in our investment solutions by identifying, evaluating and managing
relevant risks in our investment manager review process, and portfolio management and through implementing proprietary solutions. We
believe sustainability risks are most relevant to investment outcomes when they exhibit ﬁnancial materiality, and, like all investment
risks, are incorporated by balancing expected risk with expected reward.
In managing investment solutions, we consider ﬁnancially-material sustainability risks in the context of expected rewards using a blendof inputs from sources including, but not limited to, investment managers, third-party data sources and Russell Investments propriety
analysis. Furthermore, we incorporate bespoke sustainability risks based on clients’ requirements for customized mandates. As well, weseek to collaborate with our advisory clients to consider, monitor and manage sustainability risk priorities in their portfolios.

☑ (C) Management monitors and reports on climate-related risks and opportunities. Specify:

The Russell Investments Global Responsible Investing Steering Group includes the CIO and other EC members. The Steering Group
receives regular updates on our climate change research and reporting.

☑ (D) Management ensures adequate resources, including staff, training and budget, are available to assess, implement andmonitor climate-related risks/opportunities and measures. Specify:

Russell Investments has materially increased resourcing for climate-related risks/opportunities and measures through approval of current
staff research initiatives, staﬃng increases and support for data procurement.

☐ (E) Other roles management takes on to assess and manage climate-related risks/opportunities, please specify:☐ (F) Our management does not have responsibility for assessing and managing climate-related risks and opportunities

Strategy
Indicator

Type of indicator

Dependent on

Gateway toDisclosure

Subsection

PRI Principle

ISP 30CORE

N/A

Multiple, see guidance

PUBLIC

Strategy

GeneralWhich climate-related risks and opportunities has your organisation identiﬁed within its investment time horizon(s)?
☐ (A) Speciﬁc ﬁnancial risks in different asset classes. Specify:☑ (B) Speciﬁc sectors and/or assets that are at risk of being stranded. Specify:
Carbon reserves, Green energy production.

☑ (C) Assets with exposure to direct physical climate risk. Specify:
Carbon footprint, temperature alignment.

☑ (D) Assets with exposure to indirect physical climate risk. Specify:
Carbon footprint, temperature alignment.

☑ (E) Speciﬁc sectors and/or assets that are likely to beneﬁt under a range of climate scenarios. Specify:
Green energy ratio, ESG risk ratings.

☑ (F) Speciﬁc sectors and/or assets that contribute signiﬁcantly to achieving our climate goals. Specify:
Green energy ratio, ESG risk ratings.

☑ (G) Other climate-related risks and opportunities identiﬁed. Specify:
ESG qualitative assessment (ESG disaggregated rank).

61☐ (H) We have not identiﬁed speciﬁc climate-related risks and opportunities within our organisation's investment time horizon
Indicator

Type of indicator

Dependent on

Gateway toDisclosure

Subsection

PRI Principle

ISP 30.1

CORE

ISP 30N/A

PUBLIC

Strategy

GeneralFor each of the identiﬁed climate-related risks and opportunities, indicate within which investment time-horizon they wereidentiﬁed.

(1) 3–5 months(2) 6 months to
2 years(3) 2–4 years(4) 5–10 years(B) Speciﬁc sectors and/or assetsthat are at risk of being stranded [asspeciﬁed]

☐

☐

☑

☑

(C) Assets with exposure to direct
physical climate risk [as speciﬁed]

☐

☐

☐

☑

(D) Assets with exposure to indirect
physical climate risk [as speciﬁed]

☐

☐

☐

☑

(E) Speciﬁc sectors and/or assetsthat are likely to beneﬁt under arange of climate scenarios [asspeciﬁed]

☑

☑

☐

☐

(F) Speciﬁc sectors and/or assetsthat contribute signiﬁcantly toachieving our climate goals [asspeciﬁed]

☑

☑

☐

☐

(G) Other climate-related risks andopportunities identiﬁed [as speciﬁed]

☑

☑

☐

☐

(B) Speciﬁc sectors and/or assetsthat are at risk of being stranded[as speciﬁed](5) 11–20 years(6) 21–30 years(7) >30 years

☑

☑

☐

62

(C) Assets with exposure to direct
physical climate risk [as speciﬁed]

☑

☑

☐

(D) Assets with exposure toindirect physical climate risk [asspeciﬁed]☑

☑

☐(E) Speciﬁc sectors and/or assetsthat are likely to beneﬁt under arange of climate scenarios [asspeciﬁed]☐☐☐(F) Speciﬁc sectors and/or assetsthat contribute signiﬁcantly toachieving our climate goals [asspeciﬁed]☐☐☐(G) Other climate-related risks andopportunities identiﬁed [as speciﬁed]

☐

☐

☐

Indicator

Type of indicator

Dependent on

Gateway toDisclosure

Subsection

PRI Principle

ISP 31

CORE

N/A

N/A

PUBLIC

Strategy

GeneralWhich climate-related risks and opportunities has your organisation identiﬁed beyond its investment time horizon(s)?
☑ (A) Speciﬁc ﬁnancial risks in different asset classes. Specify:

We recognize that over the long term, climate-related risks and opportunities may manifest differently across different asset classes andsectors. For example, real estate, infrastructure, energy, or utility assets may be more exposed to climate-related risks and opportunities
than other asset classes and sectors.

☑ (B) Speciﬁc sectors and/or assets that are at risk of being stranded. Specify:

When speciﬁcally incorporating climate-related outcomes into our low carbon strategies, we consider a security's exposure to fossil fuelreserves as a proxy for assets at risk of being stranded.

☐ (C) Assets with exposure to direct physical climate risk. Specify:☐ (D) Assets with exposure to indirect physical climate risk. Specify:☐ (E) Speciﬁc sectors and/or assets that are likely to beneﬁt under a range of climate scenarios. Specify:☐ (F) Speciﬁc sectors and/or assets that contribute signiﬁcantly to achieving our climate goals. Specify:☑ (G) Other climate-related risks and opportunities identiﬁed, please specify:

As part of our commitment to the Net Zero Asset Manager Initiative, we will evaluate and assess climate-related risks and opportunities
across our solutions globally.

☐ (H) We have not identiﬁed speciﬁc climate-related risks and opportunities beyond our organisation's investment time horizon

63

Strategy: Scenario analysis
Indicator

Type ofindicator

Dependent on

Gateway toDisclosure

Subsection

PRI Principle

ISP 33CORE

N/A

ISP 33.1

PUBLIC

Strategy: Scenario analysis

General

Does your organisation use scenario analysis to assess climate-related investment risks and opportunities? Select the range of
scenarios used.
☑ (A) An orderly transition to a 2°C or lower scenario☑ (B) An abrupt transition consistent with the Inevitable Policy Response☑ (C) A failure to transition, based on a 4°C or higher scenario☑ (D) Other climate scenario, specify:

We are currently using publicly available information to assess transition scenarios and temperature alignment for our funds.

☐ (E) We do not use scenario analysis to assess climate-related investment risks and opportunities

Sustainability outcomesSet policies on sustainability outcomes
Indicator

Type ofindicator

DependentonGatewaytoDisclosure

Subsection

PRI
Principle

ISP 40

CORE

ISP 1.1

N/A

PUBLICSet policies on sustainability
outcomes

1, 2

Where is your approach to sustainability outcomes set out? Your policy/guideline may be a standalone document or part of awider responsible investment policy.
☐ (A) Our approach to sustainability outcomes is set out in our responsible investment policy☐ (B) Our approach to sustainability outcomes is set out in our exclusion policy☑ (C) Our approach to sustainability outcomes is set out in our stewardship policy☑ (D) Our approach to sustainability outcomes is set out in asset class–speciﬁc investment guidelines☐ (E) Our approach to sustainability outcomes is set out in separate guidelines on speciﬁc outcomes (e.g. the SDGs, climate or
human rights)

64IndicatorType ofindicator

DependentonGatewaytoDisclosure

Subsection

PRI
Principle

ISP 41

CORE

ISP 1.1

N/A

PUBLICSet policies on sustainability
outcomes

1, 2Which global or regionally recognised frameworks do your policies and guidelines on sustainability outcomes refer to?
☐ (A) The SDG goals and targets☐ (B) The Paris Agreement☐ (C) The UN Guiding Principles on Business and Human Rights☐ (D) The OECD Guidelines for Multinational Enterprises, including guidance on Responsible Business Conduct for
Institutional Investors☑ (E) Other frameworks, please specify:
UNPRI Engagement outcomes☑ (F) Other frameworks, please specify:

For bespoke mandates, we have speciﬁc guidelines that are guided by, e.g., Febelﬁn, RIAA, or by client-set criteria. In the case of
impact funds, we have worked closely with the clients to identify targeted outcomes.

Indicator

Type ofindicator

DependentonGatewaytoDisclosure

Subsection

PRI
Principle

ISP 42

PLUS

ISP 1.1

N/A

PUBLICSet policies on sustainability
outcomes

1, 2What are the main reasons that your organisation has established policies or guidelines on sustainability outcomes? Select amaximum of three options.
☐ (A) Because we understand which potential ﬁnancial risks and opportunities are likely to exist in (and during the transitionto) an SDG-aligned world☑ (B) Because we see it as a way to identify opportunities, such as through changes to business models, across supply chains
and through new and expanded products and services☐ (C) Because we want to prepare for and respond to legal and regulatory developments, including those that may lead tostranded assets☐ (D) Because we want to protect our reputation and licence-to-operate (i.e. the trust of beneﬁciaries, clients and otherstakeholders), particularly in the event of negative sustainability outcomes from investments☑ (E) Because we want to meet institutional commitments on global goals (including those based on client or beneﬁciaries'
preferences), and communicate on progress towards meeting those ob jectives☑ (F) Because we consider materiality over longer time horizons to include transition risks, tail risks, ﬁnancial system risks andsimilar☐ (G) Because we want to minimise negative sustainability outcomes and increase positive sustainability outcomes ofinvestments

65

Identify sustainability outcomes
Indicator

Type ofindicator

DependentonGateway toDisclosure

Subsection

PRI
Principle

ISP 43CORE

N/A

Multiple, seeguidance

PUBLIC

Identify sustainability
outcomes1

Has your organisation identiﬁed the intended and unintended sustainability outcomes from any of its activities?
○ (A) No, we have not identiﬁed the sustainability outcomes from our activities◉ (B) Yes, we have identiﬁed one or more sustainability outcomes from some or all of our activities
Indicator

Type ofindicator

DependentonGatewaytoDisclosure

Subsection

PRI
Principle

ISP 44

CORE

ISP 43

ISP 44.1

PUBLIC

Identify sustainability
outcomes

1

What frameworks/tools did your organisation use to identify the sustainability outcomes from its activities? Indicate the tools orframeworks you have used to identify and map some or all of your sustainability outcomes.
☐ (A) The UN Sustainable Development Goals (SDGs) and targets☐ (B) The Paris Agreement☐ (C) The UN Guiding Principles on Business and Human Rights (UNGPs)☐ (D) The OECD Guidelines for Multinational Enterprises, including guidance on Responsible Business Conduct for
Institutional Investors☐ (E) The EU Taxonomy☐ (F) Other taxonomies (e.g. similar to the EU Taxonomy), please specify:☑ (G) Other framework/tool, please specify:

PRI outcome framework for shareholder engagement. We have adopted the following categories: Company changed practice, Company
committed to change, Disclosure/report published, Fail/No Outcome, Increased understanding/Information, Ongoing, Voting. We havenot adopted "investment" or "divestment."☐ (H) Other framework/tool, please specify:☐ (I) Other framework/tool, please specify:

66IndicatorType ofindicator

DependentonGatewaytoDisclosure

Subsection

PRI
Principle

ISP 44.1

CORE

ISP 44

N/A

PUBLIC

Identify sustainability
outcomes

1

At what level(s) did your organisation identify the sustainability outcomes from its activities?
☐ (A) At the asset level☐ (B) At the economic activity level☑ (C) At the company level☐ (D) At the sector level☐ (E) At the country/region level☐ (F) At the global level☐ (G) Other level(s), please specify:☐ (H) We do not track at what level(s) our sustainability outcomes were identiﬁed
Indicator

Type ofindicator

DependentonGatewaytoDisclosure

Subsection

PRI
Principle

ISP 45CORE

ISP 43

SO 1

PUBLIC

Identify sustainability
outcomes

1

How has your organisation determined your most important sustainability outcome ob jectives?
☑ (A) Identifying sustainability outcomes that are closely linked to our core investment activities☑ (B) Consulting with key clients and/or beneﬁciaries to align with their priorities☐ (C) Assessing the potential severity (e.g. probability and amplitude) of speciﬁc negative outcomes over different timeframes☑ (D) Focusing on the potential for systemic impacts (e.g. due to high level of interconnectedness with other global challenges)☐ (E) Evaluating the potential for certain outcome ob jectives to act as a catalyst/enabler to achieve a broad range of goals (e.g.
gender or education)☐ (F) Analysing the input from different stakeholders (e.g. affected communities, civil society or similar)☑ (G) Understanding the geographical relevance of speciﬁc sustainability outcome ob jectives☐ (H) Other method, please specify:☐ (I) We have not yet determined our most important sustainability outcome ob jectives

67

Transparency & Conﬁdence-Building Measures
Information disclosed – ESG assets
Indicator

Type ofindicator

DependentonGatewaytoDisclosure

Subsection

PRI
Principle

ISP 46

CORE

OO 16

N/A

PUBLIC

Information disclosed – ESG
assets6

For the majority of your ESG/sustainability marketed funds or products, and/or your ESG/RI certiﬁed or labelled assets, what
information about your ESG approach do you (or the external investment managers/service providers acting on your behalf )include in material shared with clients, beneﬁciaries and/or the public? The material may be marketing material, information
targeted towards existing or prospective clients or information for beneﬁciaries.
☑ (A) A commitment to responsible investment (e.g. that we are a PRI signatory)☑ (B) Industry-speciﬁc and asset class–speciﬁc standards that we align with (e.g. TCFD, or GRESB for property andinfrastructure)☑ (C) Our responsible investment policy (at minimum a summary of our high-level approach)☑ (D) A description of our investment process and how ESG is considered☑ (E) ESG ob jectives of individual funds☐ (F) Information about the ESG benchmark(s) that we use to measure fund performance☑ (G) Our stewardship approach☐ (H) A description of the ESG criteria applied (e.g. sectors, products, activities, ratings and similar)☑ (I) The thresholds for the ESG criteria applied in our investment decisions or universe construction☑ (J) A list of our main investments and holdings☑ (K) ESG case study/example from existing fund(s)☐ (L)We do not include our approach to ESG in material shared with clients/beneﬁciaries/the public for the majority of our
ESG/sustainability marketed funds or products, and/or our ESG/RI certiﬁed or labelled assets

68Client reporting – ESG assets
Indicator

Type ofindicator

Dependent on

GatewaytoDisclosure

Subsection

PRI
Principle

ISP 48

CORE

Multiple, seeguidance

N/A

PUBLIC

Client reporting – ESG
assets6

What ESG information is included in your client reporting for the majority of your ESG/sustainability marketed funds or
products, and/or your ESG/RI certiﬁed or labelled assets?
☑ (A) Qualitative analysis, descriptive examples or case studies☑ (B) Quantitative analysis or key performance indicators (KPIs) related to ESG performance☑ (C) Progress on our sustainability outcome ob jectives☑ (D) Stewardship results☐ (E) Information on ESG incidents, where applicable☐ (F) Analysis of ESG contribution to portfolio ﬁnancial performance☐ (G) We do not include ESG information in client reporting for the majority of our ESG/sustainability marketed funds or
products, and/or our ESG/RI certiﬁed or labelled assets

Information disclosed – All assets
Indicator

Type ofindicator

DependentonGatewaytoDisclosure

Subsection

PRI
Principle

ISP 49

CORE

N/A

N/A

PUBLIC

Information disclosed – All
assets6

For the majority of your total assets under management, what information about your ESG approach do you (or the externalmanagers/service providers acting on your behalf ) include in material shared with clients, beneﬁciaries and/or the public? The
material may be marketing material, information targeted towards existing or prospective clients or information for beneﬁciaries.
☑ (A) A commitment to responsible investment (e.g. that we are a PRI signatory)☑ (B) Industry-speciﬁc and asset class–speciﬁc standards that we align with (e.g. TCFD, or GRESB for property andinfrastructure)☑ (C) Our responsible investment policy (at minimum a summary of our high-level approach)☑ (D) A description of our investment process and how ESG is considered☐ (E) ESG ob jectives of individual funds☐ (F) Information about the ESG benchmark(s) that we use to measure fund performance☑ (G) Our stewardship approach☐ (H) A description of the ESG criteria applied (e.g. sectors, products, activities, ratings and similar)☐ (I) The thresholds for the ESG criteria applied in our investment decisions or universe construction☑ (J) A list of our main investments and holdings☐ (K) ESG case study/example from existing fund(s)69☐ (L) We do not include our approach to ESG in material shared with clients/beneﬁciaries/the public for the majority of ourassets under management

Client reporting – All assets
Indicator

Type ofindicator

Dependent on

GatewaytoDisclosure

Subsection

PRI
Principle

ISP 50

CORE

Multiple, seeguidance

N/A

PUBLIC

Client reporting – All
assets6

What ESG information is included in your client reporting for the majority of your assets under management?
☑ (A) Qualitative ESG analysis, descriptive examples or case studies☑ (B) Quantitative analysis or key performance indicators (KPIs) related to ESG performance☐ (C) Progress on our sustainability outcome ob jectives☑ (D) Stewardship results☐ (E) Information on ESG incidents where applicable☐ (F) Analysis of ESG contribution to portfolio ﬁnancial performance☐ (G) We do not include ESG information in client reporting for the majority of our assets under management

Frequency of client reporting – All assets
Indicator

Type ofindicator

Dependent on

GatewaytoDisclosure

Subsection

PRI
Principle

ISP 51

CORE

Multiple, seeguidance

N/A

PUBLICFrequency of client reporting –All assets

6

For the majority of each asset class, how frequently do you report ESG-related information to your clients?
(A) Listed equity(1) Quarterly

70

Conﬁdence-building measures
Indicator

Type ofindicator

DependentonGateway toDisclosure

Subsection

PRI
Principle

ISP 52CORE

OO 16.1

Multiple, seeguidance

PUBLICConﬁdence-building
measures

6

What veriﬁcation has your organisation had regarding the information you have provided in your PRI Transparency Report thisyear?
☑ (A) We received third-party independent assurance of selected processes and/or data related to our responsible investment
processes, which resulted in a formal assurance conclusion☐ (B) We conducted a third-party readiness review and are making changes to our internal controls/governance or processes tobe able to conduct an external assurance next year
☑ (C) The internal audit function team performed an independent audit of selected processes/and or data related to our
responsible investment processes reported in this PRI report☑ (D) Our board, CEO, other C-level equivalent and/or investment committee has signed off on our PRI report☑ (E) Some or all of our funds have been audited as part of the certiﬁcation process against a sustainable investment/RI label☐ (F) We conducted an external ESG audit of our ESG/sustainability marketed funds or products (excluding ESG/RI certiﬁed
or labelled assets)☐ (G) We conducted an external ESG audit of our holdings to check that our funds comply with our RI policy (e.g. exclusion list
or investee companies in portfolio above certain ESG rating)☐ (H) We conducted an external ESG audit of our holdings as part of risk management, engagement identiﬁcation or investment
decision-making☑ (I) Responses related to our RI practices documented in this report have been internally reviewed before submission to the
PRI☐ (J) None of the above
Indicator

Type ofindicator

DependentonGatewaytoDisclosure

Subsection

PRI
Principle

ISP 53CORE

ISP 52, OO
14N/A

PUBLICConﬁdence-building
measures

6

Which responsible investment processes and/or data did your organisation have third-party external assurance on?

(A) Investment and stewardship policy(3) Processes and related data
assured(B) Manager selection, appointment and monitoring(1) Processes assured(C) Listed equity(3) Processes and related data
assured71

IndicatorType ofindicator

DependentonGatewaytoDisclosure

Subsection

PRI
Principle

ISP 54CORE

ISP 52

ISP 54.1

PUBLICConﬁdence-building
measures

6

What standard did your third-party external assurance provider use?
☐ (A) PAS 7341:2020☐ (B) ISAE 3000 and national standards based on this☐ (C) Dutch Standard 3810N (Assurance engagements regarding sustainability reports)☐ (D) RevR6 (Assurance of Sustainability)☐ (E) IDW AsS 821 (Assurance Standard for the Audit or Review of Reports on Sustainability Issues)☐ (F) Accountability AA1000 Assurance Standard (AA1000AS)☐ (G) IFC performance standards☐ (H) SSAE 18 and SOC 1☑ (I) Other national auditing/assurance standard with guidance on sustainability, please specify:
RIAA☐ (J) Invest Europe Handbook of Professional Standards☐ (K) ISAE 3402
☐ (L) AAF 01/06☐ (M) AAF 01/06 Stewardship Supplement☐ (N) ISO 26000 Social Responsibility☐ (O) ASAE 3410 Assurance Engagements on Greenhouse Gas Statements☐ (P) PCAF
☐ (Q) NGERS audit framework (National Greenhouse and Energy Reporting)☐ (R) Auditor’s proprietary assurance framework for assuring RI-related information☐ (S) Other greenhouse gas emissions assurance standard, please specify:☐ (T) None of the above
Indicator

Type ofindicator

DependentonGatewaytoDisclosure

Subsection

PRI
Principle

ISP 54.1

PLUS

ISP 54

N/A

PUBLICConﬁdence-building
measures6

Attach your third-party external assurance provider's report that contains the assurance conclusion.
File uploaded: https://priassociation.eu.qualtrics.com/ControlPanel/File.php?F=F_Cd9JCiLPO45pwwF72

IndicatorType ofindicator

DependentonGatewaytoDisclosure

Subsection

PRI
Principle

ISP 55

PLUS

ISP 52

N/A

PUBLICConﬁdence-building
measures6

Provide details of the third-party external assurance. Include details such as the level of assurance attained, who conducted it,
limitations, the expertise of the assurer in the sub ject matter and/or usage of multiple standards.
https://www.responsiblereturns.com.au/investment-managers/russell-investments/proﬁleIndicator

Type ofindicator

DependentonGatewaytoDisclosure

Subsection

PRI
Principle

ISP 56CORE

OO 14, ISP
52

N/A

PUBLICConﬁdence-building
measures

6

What responsible investment processes and/or data were audited by internal auditors/outsourced internal auditors?

(A) Investment and stewardship policy(3) Processes and related data
assured(B) Manager selection, appointment and monitoring(1) Processes assured(C) Listed equity(3) Processes and related data
assured73

IndicatorType ofindicator

DependentonGatewaytoDisclosure

Subsection

PRI
Principle

ISP 57

PLUS

ISP 52

N/A

PUBLICConﬁdence-building
measures6

Provide details about the internal audit process regarding the information provided in your PRI Transparency Report.
The purpose of the Russell Investments Group Internal Audit function is to provide independent, objective assurance and consulting
services designed to improve the organisation’s controls and operations. Internal Audit accomplishes this by providing risk-based andobjective assurance, advice and insight to enhance and protect organisational value. Internal Audit helps the organisation accomplish
its objectives by bringing a systematic, disciplined approach to test, evaluate, and improve the effectiveness of governance, risk
management and control processes.
The Russell Investments Group Internal Audit function utilises a risk-based approach in developing the annual audit plan. The audit
universe of key processes is assessed to focus the audit plan on the areas of highest risk. Any issues identiﬁed by Internal Audit require
management action plans (MAPs) and are tracked to resolution by Internal Audit. The status of open issues is regularly reported to
relevant boards and audit committees. Internal Audit validates resolution to close identiﬁed issues.
Internal Audit conducts structured reviews of key processes and risks, including detailed testing of mitigating controls across theorganisation. These audits are designed to assess if systems and procedures are effective, eﬃcient and function as designed, thereby
helping ensure:•risks are appropriately identiﬁed and managed•
quality and continuous improvement are fostered in the organisation’s control process•
signiﬁcant ﬁnancial, managerial, and operating information is prepared accurately and reliably•
resources are adequately protected

Indicator

Type ofindicator

DependentonGatewaytoDisclosure

Subsection

PRI
Principle

ISP 58CORE

ISP 52

N/A

PUBLICConﬁdence-building
measures6

Who has reviewed/veriﬁed the entirety of or selected data from your PRI report?
(A) Board and/or trustees(4) report not reviewed(B) Chief-level staff (e.g. Chief Executive Oﬃcer (CEO), Chief Investment Oﬃcer (CIO)
or Chief Operating Oﬃcer (COO))(1) the entire report(C) Investment committee(1) the entire report(D) Other chief-level staff, please specify:
Head of EMEA business(1) the entire report74(E) Head of department, please specify:
Head of Responsible Investing, Head of Research, Head of Portfolio Management(1) the entire report(F) Compliance/risk management team(4) report not reviewed(G) Legal team(1) the entire report(H) RI/ ESG team(1) the entire report(I) Investment teams(3) parts of the report

Indicator

Type ofindicator

DependentonGatewaytoDisclosure

Subsection

PRI
Principle

ISP 59CORE

ISP 52

N/A

PUBLICConﬁdence-building
measures

6

Which of the following ESG/RI certiﬁcations or labels do you hold?
☐ (A) Commodity type label (e.g. BCI)
☐ (B) GRESB☐ (C) Austrian Ecolabel (UZ49)☐ (D) B Corporation☐ (E) BREEAM☐ (F) CBI Climate Bonds Standard☐ (G) EU Ecolabel☐ (H) EU Green Bond Standard☐ (I) Febelﬁn label (Belgium)☐ (J) FNG-Siegel Ecolabel (Germany, Austria and Switzerland)☐ (K) Greenﬁn label (France)☐ (L) ICMA Green Bond Principles☐ (M) Le label ISR (French government SRI label)☐ (N) Luxﬂag Climate Finance☐ (O) Luxﬂag Environment☐ (P) Luxﬂag ESG☐ (Q) Luxﬂag Green Bond
☐ (R) Luxﬂag Microﬁnance☐ (S) National stewardship code (e.g. UK or Japan), please specify:☐ (T) Nordic Swan Ecolabel☐ (U) Other SRI label based on EUROSIF SRI Transparency Code (e.g. Novethic), please specify:☐ (V) People's Bank of China green bond guidelines☑ (W) RIAA (Australia)☐ (X) Towards Sustainability label (Belgium)☐ (Y) Other, please specify:

75

Manager Selection, Appointment and Monitoring(SAM)
Selection
Responsible investment policy
Indicator

Type ofindicator

DependentonGatewaytoDisclosure

Subsection

PRI
Principle

SAM 2

CORE

OO 11

SAM 2.1

PUBLIC

Responsible investment
policy1, 4During the reporting year, did your organisation include compliance with your responsible investment policy as a pre-requisitewhen selecting external managers? (If you did not select any external managers during the reporting year, refer to the lastreporting year in which you did select external managers.)(1) Yes, only whenselecting externalmanagers of
ESG/sustainability
funds(2) Yes, when selecting
external managers of
ESG/sustainability
funds and mainstream
funds (This option also
applies to signatories
who may not hold
ESG/sustainability
funds)(3) We did not include
compliance with our
responsible investment
policy as a pre-requisitewhen selecting externalmanagers(A) Listed equity (active)

◉

○

○

(C) Fixed income (active)

◉

○

○

(E) Private equity

◉

○

○

(F) Real estate

◉

○

○

(G) Infrastructure

◉

○

○

(H) Hedge funds

○

○

◉

76

IndicatorType ofindicator

DependentonGatewaytoDisclosure

Subsection

PRI
Principle

SAM 2.1

CORE

SAM 2

N/A

PUBLIC

Responsible investment
policy1,4In what proportion of cases did your organisation include compliance with your responsible investment policy as a pre-requisitewhen selecting external managers?
(1) Listed equity (active)(A) When selecting external managers of ESG/sustainability funds(2) in the majority of cases(3) Fixed income (active)(A) When selecting external managers of ESG/sustainability funds(1) in all cases(5) Private equity(A) When selecting external managers of ESG/sustainability funds(1) in all cases(6) Real estate(A) When selecting external managers of ESG/sustainability funds(1) in all cases(7) Infrastructure(A) When selecting external managers of ESG/sustainability funds(1) in all cases

77Research and screening
Indicator

Type of indicator

Dependent on

Gateway toDisclosure

Subsection

PRI Principle

SAM 3

CORE

OO 11

N/A

PUBLIC

Research and screening

1

When selecting external managers, which aspects of their organisation do you, or the investment consultant acting on yourbehalf, assess against responsible investment criteria? (Per asset class, indicate the proportion of your AUM to which each ofthese selection practices applies, regardless of when you selected your different external managers.)(1) Listed equity (active)(3) Fixed income (active)(A) Firm culture(1) for all of our externally managed AUM(1) for all of our externally managed AUM(B) Investment
approach, ob jectives
and philosophy(1) for all of our externally managed AUM(1) for all of our externally managed AUM(C) Investment policy
or guidelines(1) for all of our externally managed AUM(1) for all of our externally managed AUM(D) Governancestructure andmanagement oversight,
including diversity(1) for all of our externally managed AUM(1) for all of our externally managed AUM(E) Investment
strategy and fundstructure(1) for all of our externally managed AUM(1) for all of our externally managed AUM(F) Investment teamcompetencies(1) for all of our externally managed AUM(1) for all of our externally managed AUM(G) Other, please
specify:(A) Firm cultureNANA(1) for all of our externally managed AUM(1) for all of our externally managed AUM(5) Private equity(6) Real estate(1) for all of our externally managed AUM(1) for all of our externally managed AUM

78

(B) Investment
approach, ob jectives
and philosophy(1) for all of our externally managed AUM(1) for all of our externally managed AUM(C) Investment policy
or guidelines(1) for all of our externally managed AUM(1) for all of our externally managed AUM(D) Governancestructure andmanagement oversight,
including diversity(1) for all of our externally managed AUM(1) for all of our externally managed AUM(E) Investment
strategy and fundstructure(1) for all of our externally managed AUM(1) for all of our externally managed AUM(F) Investment teamcompetencies(1) for all of our externally managed AUM(1) for all of our externally managed AUM(G) Other, please
specify:NANA(1) for all of our externally managed AUM(1) for all of our externally managed AUM(7) Infrastructure(8) Hedge Funds(A) Firm culture(1) for all of our externally managed AUM(1) for all of our externally managed AUM(B) Investment
approach, ob jectives
and philosophy(1) for all of our externally managed AUM(1) for all of our externally managed AUM(C) Investment policy
or guidelines(1) for all of our externally managed AUM(1) for all of our externally managed AUM(D) Governancestructure andmanagement oversight,
including diversity(1) for all of our externally managed AUM(1) for all of our externally managed AUM(E) Investment
strategy and fundstructure(1) for all of our externally managed AUM(1) for all of our externally managed AUM(F) Investment teamcompetencies(1) for all of our externally managed AUM(1) for all of our externally managed AUM

79

(G) Other, please
specify:NANA(1) for all of our externally managed AUM(1) for all of our externally managed AUM

Investment practices
Indicator

Type of indicator

Dependent on

Gateway toDisclosure

Subsection

PRI Principle

SAM 4

CORE

OO 11

N/A

PUBLIC

Investment practices

1

Which responsible investment practices does your organisation, or the investment consultants acting on your behalf, require aspart of your external manager selection criteria? (Per asset class, indicate the proportion of your AUM to which each of theseselection practices applies, regardless of when you selected your different external managers.) As part of the selection criteria, we
require that external managers:(1) Listed equity (active)(3) Fixed income (active)(A) Incorporatematerial ESG factors
in all of theirinvestment analyses
and decisions(2) for the majority of our externallymanaged AUM(2) for the majority of our externally managed
AUM(B) Incorporate theirown responsible
investment policy into
their asset allocation
decisions(2) for the majority of our externallymanaged AUM(2) for the majority of our externally managed
AUM(C) Have adequate
resources andprocesses to analyse
ESG factors(2) for the majority of our externallymanaged AUM(2) for the majority of our externally managed
AUM(D) Incorporatematerial ESG factors
throughout theirportfolio construction(2) for the majority of our externallymanaged AUM(2) for the majority of our externally managed
AUM

80

(E) Engage with
underlying portfolio
assets to address ESG
risks and opportunities(2) for the majority of our externallymanaged AUM(2) for the majority of our externally managed
AUM(F) Comply with theirown exclusions policy(1) for all of our externally managed AUM(2) for the majority of our externally managed
AUM(G) Embed ESG
considerations incontractual
documentation(3) for a minority of our externally managed
AUM(2) for the majority of our externally managed
AUM(H) Implement
adequate disclosureand accountability
mechanisms(1) for all of our externally managed AUM(1) for all of our externally managed AUM(I) Are willing to workin partnership with
our organisation todevelop their
responsible investment
approach(3) for a minority of our externally managed
AUM(2) for the majority of our externally managed
AUM(J) Track the positive
and negative
sustainability
outcomes of theiractivities(3) for a minority of our externally managed
AUM(3) for a minority of our externally managed
AUM(K) Other, please
specify:(A) Incorporatematerial ESG factors
in all of theirinvestment analyses
and decisionsNANA(1) for all of our externally managed AUM(1) for all of our externally managed AUM(5) Private equity(6) Real estate(3) for a minority of our externally managed
AUM(2) for the majority of our externally managed
AUM

81

(B) Incorporate theirown responsible
investment policy into
their asset allocation
decisions(3) for a minority of our externally managed
AUM(2) for the majority of our externally managed
AUM(C) Have adequate
resources andprocesses to analyse
ESG factors(3) for a minority of our externally managed
AUM(2) for the majority of our externally managed
AUM(D) Incorporatematerial ESG factors
throughout theirportfolio construction(3) for a minority of our externally managed
AUM(2) for the majority of our externally managed
AUM(E) Engage with
underlying portfolio
assets to address ESG
risks and opportunities(3) for a minority of our externally managed
AUM(2) for the majority of our externally managed
AUM(F) Comply with theirown exclusions policy(1) for all of our externally managed AUM(1) for all of our externally managed AUM(G) Embed ESG
considerations incontractual
documentation(3) for a minority of our externally managed
AUM(2) for the majority of our externally managed
AUM(H) Implement
adequate disclosureand accountability
mechanisms(1) for all of our externally managed AUM(1) for all of our externally managed AUM(I) Are willing to workin partnership with
our organisation todevelop their
responsible investment
approach(3) for a minority of our externally managed
AUM(3) for a minority of our externally managed
AUM(J) Track the positive
and negative
sustainability
outcomes of theiractivities(3) for a minority of our externally managed
AUM(2) for the majority of our externally managed
AUM

82

(K) Other, please
specify:NANA(1) for all of our externally managed AUM(1) for all of our externally managed AUM(7) Infrastructure(8) Hedge funds(A) Incorporatematerial ESG factors
in all of theirinvestment analyses
and decisions(2) for the majority of our externallymanaged AUM(1) for all of our externally managed AUM(B) Incorporate theirown responsible
investment policy into
their asset allocation
decisions(2) for the majority of our externallymanaged AUM(3) for a minority of our externally managed
AUM(C) Have adequate
resources andprocesses to analyse
ESG factors(2) for the majority of our externallymanaged AUM(3) for a minority of our externally managed
AUM(D) Incorporatematerial ESG factors
throughout theirportfolio construction(2) for the majority of our externallymanaged AUM(3) for a minority of our externally managed
AUM(E) Engage with
underlying portfolio
assets to address ESG
risks and opportunities(2) for the majority of our externallymanaged AUM(3) for a minority of our externally managed
AUM(F) Comply with theirown exclusions policy(1) for all of our externally managed AUM(1) for all of our externally managed AUM(G) Embed ESG
considerations incontractual
documentation(3) for a minority of our externally managed
AUM(3) for a minority of our externally managed
AUM(H) Implement
adequate disclosureand accountability
mechanisms(1) for all of our externally managed AUM(1) for all of our externally managed AUM

83

(I) Are willing to workin partnership with
our organisation todevelop their
responsible investment
approach(3) for a minority of our externally managed
AUM(3) for a minority of our externally managed
AUM(J) Track the positive
and negative
sustainability
outcomes of theiractivities(3) for a minority of our externally managed
AUM(3) for a minority of our externally managed
AUM(K) Other, please
specify:NANA(1) for all of our externally managed AUM(1) for all of our externally managed AUM

Indicator

Type of indicator

Dependent on

Gateway toDisclosure

Subsection

PRI Principle

SAM 5

PLUS

OO 11

N/A

PUBLIC

Investment practices

1

Does your organisation, or the investment consultants acting on your behalf, expressly assess the following practices regarding
derivatives and short positions as part of your manager selection process? (Indicate the proportion of your AUM to which eachof these selection practices applies, regardless of when you selected your different external managers.)(A) We assess whether they apply ESG incorporation into derivatives, insurance
instruments (such as CDS) and other synthetic exposures or positions(2) for all of our externallymanaged AUM(B) We assess how they apply their exclusion policies to short and derivative exposures(2) for all of our externallymanaged AUM(C) We assess whether their use of leverage is aligned with their responsible investment
policy(2) for all of our externallymanaged AUM

84

Sustainability outcomes
Indicator

Type of indicator

Dependent on

Gateway toDisclosure

Subsection

PRI Principle

SAM 10

PLUS

OO 11

N/A

PUBLIC

Sustainability outcomes1

How does your organisation, or the investment consultant acting on your behalf, assess external managers' approaches to theirsustainability outcomes as part of your selection process? (Indicate the proportion of your AUM to which each of these selection
practices applies, regardless of when you selected your different external managers.)(A) We assess their track records on advancing sustainability outcomes across theirassets(1) for all of our externallymanaged AUM(B) We assess whether they have set targets for the sustainability outcomes of theiractivities or are willing to incorporate our own targets(1) for all of our externallymanaged AUM(C) We assess how they use key levers including asset allocation, engagement andstewardship activities to advance sustainability outcomes(1) for all of our externallymanaged AUM(D) We assess how well they report on their progress on sustainability outcomes acrosstheir assets(1) for all of our externallymanaged AUM

Documentation and track record
Indicator

Type ofindicator

DependentonGatewaytoDisclosure

Subsection

PRI
Principle

SAM 11

CORE

OO 11

N/A

PUBLIC

Documentation and trackrecord1

As part of your selection process, which documents does your organisation, or the investment consultants acting on your behalf,
review to gain conﬁdence in external managers' responsible investment practices? (Indicate the proportion of your AUM to which
each of these selection practices applies, regardless of when you selected your different external managers.)(A) Standard client reporting, responsible investment reports or impact reports(1) for all of our externallymanaged AUM

85

(B) Responsible investment methodology and its inﬂuence on past investment decisions(1) for all of our externallymanaged AUM(C) Historical voting and engagement activities with investees(2) for the majority of ourexternally managed AUM(D) Historical engagement activities with policymakers(3) for a minority of our externallymanaged AUM(E) Compliance manuals and portfolios to ensure universal construction rules areapplied (e.g. exclusions, thematic, best-in-class deﬁnitions and thresholds)(3) for a minority of our externallymanaged AUM(F) Controversies and incidence reports(3) for a minority of our externallymanaged AUM(G) Code of conduct or codes of ethics(2) for the majority of ourexternally managed AUM(H) Other, please specify:
Because we custody the ma jority of listed equity assets, points A-H relate to our own
policies rather than the policies of our subadvisors. From that perspective, we would answer(1) for all of our externally managed AUM.

(1) for all of our externallymanaged AUM

Appointment
Pooled funds
Indicator

Type of indicator

Dependent on

Gateway toDisclosure

Subsection

PRI Principle

SAM 12CORE

OO 12, OO 5.1, OO 15

N/A

PUBLIC

Pooled funds

4

How did your organisation, or the investment consultants acting on your behalf, include responsible investment requirements forpooled funds in your current contracts with external managers? (Indicate the proportion of your AUM invested in pooled funds
to which each of these requirements applies, regardless of when you appointed your different external managers.)(A) We amended or instituted side letters or equivalent legal documentation to include
responsible investment requirements(1) for all of our AUM invested inpooled funds

86

(B) We encouraged the external manager to include responsible investment
requirements into the investment mandate, the investment management agreement orequivalent legal documentation(1) for all of our AUM invested inpooled funds

Segregated mandates
Indicator

Type of indicator

Dependent on

Gateway toDisclosure

Subsection

PRI Principle

SAM 13CORE

OO 12, OO 5.1

N/A

PUBLIC

Segregated mandates

4

When setting up segregated mandates with external managers, which responsible investment clauses did your organisation, or
the investment consultants acting on your behalf, include in your current contractual agreements? (Indicate the proportion ofyour AUM invested in segregated funds to which each of these requirements applies, regardless of when you appointed yourdifferent external managers.)(A) The manager's commitment to follow our responsible investment strategy in the
management of our assets(3) for a minority of our AUM
invested in segregated mandates(B) The manager's commitment to incorporate material ESG factors into its
investment and stewardship activities(3) for a minority of our AUM
invested in segregated mandates(C) Exclusion list(s)(3) for a minority of our AUM
invested in segregated mandates(D) Responsible investment communication and reporting obligations, including on
stewardship activities and results(3) for a minority of our AUM
invested in segregated mandates(E) Stewardship commitments in line with the PRI's guidance and focused on seeking
sustainability outcomes and prioritising common goals and collaborative action(4) for none of our AUM invested
in segregated mandates(F) Where applicable, commitment to fulﬁl a clear policy on security lending alignedwith our own security lending policy or with the ICGN Securities Lending Code of Best
Practice(2) for the majority of our AUM
invested in segregated mandates(G) Incentives and controls to ensure alignment of interests(1) for all of our AUM invested insegregated mandates(H) Commitments on climate-related disclosure in line with internationally recognised
frameworks such as the TCFD

(4) for none of our AUM invested
in segregated mandates(I) If applicable, commitment to disclose against the EU Taxonomy(4) for none of our AUM invested
in segregated mandates87

(J) Commitment to respect human rights as deﬁned in the OECD Guidelines forMultinational Enterprises and the UN Guiding Principles on Business and Human
Rights(4) for none of our AUM invested
in segregated mandates(K) The manager's acknowledgement that their appointment was conditional on their
fulﬁlment of their responsible investment obligations(3) for a minority of our AUM
invested in segregated mandates(L) Other, please specify:(4) for none of our AUM invested
in segregated mandates

n/aMonitoring
Investment practices
Indicator

Type of indicator

Dependent on

Gateway toDisclosure

Subsection

PRI Principle

SAM 14

CORE

OO 13

N/A

PUBLIC

Investment practices

1

During the reporting year, which aspects of your external manager's responsible investment practices did you, or your investment
consultant acting on your behalf, monitor?
(1) Listed equity (active)(3) Fixed income (active)(A) We monitored
their alignment with
our organisation's
responsible investment
strategy(1) for all of our externally managed AUM(1) for all of our externally managed AUM(B) We monitored anychanges in their
responsible
investment–related
policies, resourcing,oversight andresponsibilities orinvestment processes(1) for all of our externally managed AUM(1) for all of our externally managed AUM(C) We monitored
their use of ESG data,
benchmarks, tools andcertiﬁcations(1) for all of our externally managed AUM(1) for all of our externally managed AUM

88

(D) We monitored how
ESG incorporation
affected investment
decisions(1) for all of our externally managed AUM(1) for all of our externally managed AUM(E) We monitored how
ESG incorporation
affected the fund's
ﬁnancial and ESG
performance(1) for all of our externally managed AUM(1) for all of our externally managed AUM(F) We monitored anychanges in ESG risk
management processes(1) for all of our externally managed AUM(1) for all of our externally managed AUM(G) We monitored
their response tomaterial ESG incidents(1) for all of our externally managed AUM(1) for all of our externally managed AUM(H) Other, please
specify:NANA(1) for all of our externally managed AUM(1) for all of our externally managed AUM(5) Private equity(6) Real estate(A) We monitored
their alignment with
our organisation's
responsible investment
strategy(1) for all of our externally managed AUM(1) for all of our externally managed AUM(B) We monitored anychanges in their
responsible
investment–related
policies, resourcing,oversight andresponsibilities orinvestment processes(1) for all of our externally managed AUM(1) for all of our externally managed AUM(C) We monitored
their use of ESG data,
benchmarks, tools andcertiﬁcations(1) for all of our externally managed AUM(1) for all of our externally managed AUM

89

(D) We monitored how
ESG incorporation
affected investment
decisions(1) for all of our externally managed AUM(1) for all of our externally managed AUM(E) We monitored how
ESG incorporation
affected the fund's
ﬁnancial and ESG
performance(1) for all of our externally managed AUM(1) for all of our externally managed AUM(F) We monitored anychanges in ESG risk
management processes(1) for all of our externally managed AUM(1) for all of our externally managed AUM(G) We monitored
their response tomaterial ESG incidents(1) for all of our externally managed AUM(1) for all of our externally managed AUM(H) Other, please
specify:NANA(1) for all of our externally managed AUM(1) for all of our externally managed AUM(7) Infrastructure(8) Hedge funds(A) We monitored
their alignment with
our organisation's
responsible investment
strategy(1) for all of our externally managed AUM(1) for all of our externally managed AUM(B) We monitored anychanges in their
responsible
investment–related
policies, resourcing,oversight andresponsibilities orinvestment processes(1) for all of our externally managed AUM(1) for all of our externally managed AUM(C) We monitored
their use of ESG data,
benchmarks, tools andcertiﬁcations(1) for all of our externally managed AUM(1) for all of our externally managed AUM

90

(D) We monitored how
ESG incorporation
affected investment
decisions(1) for all of our externally managed AUM(1) for all of our externally managed AUM(E) We monitored how
ESG incorporation
affected the fund's
ﬁnancial and ESG
performance(1) for all of our externally managed AUM(1) for all of our externally managed AUM(F) We monitored anychanges in ESG risk
management processes(1) for all of our externally managed AUM(1) for all of our externally managed AUM(G) We monitored
their response tomaterial ESG incidents(1) for all of our externally managed AUM(1) for all of our externally managed AUM(H) Other, please
specify:NANA(1) for all of our externally managed AUM(1) for all of our externally managed AUM

Indicator

Type of indicator

Dependent on

Gateway toDisclosure

Subsection

PRI Principle

SAM 16

PLUS

OO 13

N/A

PUBLIC

Investment practices

1

Provide an example of a leading practice you adopted as part of your monitoring of your external managers’ responsible
investment practices in private equity, real estate and/ or infrastructure during the reporting year.
Please provide examples below:

91

(A) Private equity

During initial due diligence we review a copy of theorganizations ESG policy, ask the manager to complete an
ESG focused RFI and hold a one-to-one meeting with theteam responsible for ESG to understand how ESG is
integrated into their investment process. Once invested weregularly monitor the managers approach against their policy
and feedback provided in the RFI and one-to-one. In private
equity for healthcare investments within our impact
mandates, we monitor a number of environmental and social
KPIs such as, number of patients screened, number ofpatients completed treatment, number of patients with newaccess, number of patients with a decrease in their healthcare
expenditure, number of full-time roles ﬁlled by women or
minorities. This data is collected annually and discussed withthe manager to ensure they are making a concerted effort toimprove and create a positive impact.

(B) Real estate

During initial due diligence we review a copy of theorganizations ESG policy, ask the manager to complete an
ESG focused RFI and hold a one-to-one meeting with theteam responsible for ESG to understand how ESG is
integrated into their investment process. Once invested weregularly monitor the managers approach against their policy
and feedback provided in the RFI and one-to-one. For realestate investments we monitor third-party certiﬁcations suchas GRESB, BREEAM, NABERS and LEED. This data iscollected annually and discussed with the manager to ensure
they are making a concerted effort to improve and create apositive impact.

(C) Infrastructure

During initial due diligence we review a copy of theorganizations ESG policy, get the manager to complete an
ESG focused RFI and hold a one-to-one meeting with theteam responsible for ESG to understand how ESG is
integrated into their investment process. Once invested weregularly monitor the managers approach against their policy
and feedback provided in the RFI and one-to-one. For
renewable infrastructure investments within our impact
mandates, we monitor a number of environmental and social
KPIs such as GHG emissions (tons sequestered and tons
avoided), renewable energy generated, number of full-timeroles ﬁlled by women or minorities. This data is collectedannually and discussed with the manager to ensure they aremaking a concerted effort to improve and create a positive
impact.

92

Sustainability outcomes
Indicator

Type of indicator

Dependent on

Gateway toDisclosure

Subsection

PRI Principle

SAM 19

PLUS

OO 13

N/A

PUBLIC

Sustainability outcomes1

During the reporting year, how did your organisation, or the investment consultants acting on your behalf, monitor yourexternal managers' progress on sustainability outcomes?
☐ (A) We reviewed progress on the sustainability outcomes of their activities☐ (B) We reviewed how they used asset allocation individually or in partnership with others to make progress on sustainability
outcomes☑ (C) We reviewed how they used individual or collaborative investee engagement, including voting, to make progress on
sustainability outcomes☑ (D) We reviewed how they used individual or collaborative systemic stewardship, including policy engagement, to makeprogress on sustainability outcomes☐ (E) We reviewed how they contributed to public goods (such as research) or public discourse (such as media) or collaborated
with other actors to track and communicate progress against global sustainability goals☑ (F) Other, please specify:
For bespoke mandates we have reviewed progress on sustainability outcomes of their activities and how they contributed to public
goods, public discourse, and collaborated with other actors to track and communicate progress against speciﬁc sustainability goals.

☐ (G) We did not review their progress on sustainability outcomes

Review
Indicator

Type of indicator

Dependent on

Gateway toDisclosure

Subsection

PRI Principle

SAM 20

CORE

OO 13

N/A

PUBLIC

Review1

During the reporting year, how often did your organisation, or the investment consultants acting on your behalf, require yourexternal managers to report to you on their responsible investment practices?
(1) Listed equity (active)(3) Fixed income (active)(A) Quarterly or more
often(1) for all of our externally managed AUM(1) for all of our externally managed AUM(B) Every six months(4) for none of our externally managed AUM(4) for none of our externally managed AUM(C) Annually(4) for none of our externally managed AUM(4) for none of our externally managed AUM

93

(D) Less than once a
year(4) for none of our externally managed AUM(4) for none of our externally managed AUM(E) On an ad hoc
basis (e.g. wheneversigniﬁcant changes,
incidents or ESGlinked events occur)(4) for none of our externally managed AUM(4) for none of our externally managed AUM(5) Private equity(6) Real estate(A) Quarterly or more
often(1) for all of our externally managed AUM(1) for all of our externally managed AUM(B) Every six months(4) for none of our externally managed AUM(4) for none of our externally managed AUM(C) Annually(4) for none of our externally managed AUM(4) for none of our externally managed AUM(D) Less than once a
year(4) for none of our externally managed AUM(4) for none of our externally managed AUM(E) On an ad hoc
basis (e.g. wheneversigniﬁcant changes,
incidents or ESGlinked events occur)(4) for none of our externally managed AUM(4) for none of our externally managed AUM(7) Infrastructure(8) Hedge funds(A) Quarterly or more
often(1) for all of our externally managed AUM(1) for all of our externally managed AUM(B) Every six months(4) for none of our externally managed AUM(4) for none of our externally managed AUM(C) Annually(4) for none of our externally managed AUM(4) for none of our externally managed AUM(D) Less than once a
year(4) for none of our externally managed AUM(4) for none of our externally managed AUM

94

(E) On an ad hoc
basis (e.g. wheneversigniﬁcant changes,
incidents or ESGlinked events occur)(4) for none of our externally managed AUM(4) for none of our externally managed AUM

Engagement and escalation
Indicator

Type ofindicator

DependentonGatewaytoDisclosure

Subsection

PRI Principle

SAM 22

CORE

OO 13

N/A

PUBLICEngagement andescalation

1

Which actions does your organisation, or the investment consultants acting on your behalf, include in its formal escalation
process to address concerns raised during monitoring?

(A) We notify the external manager
about their placement on a watch
list

(1)
Listedequity(active)(3)
Fixedincome(active)(5)
Privateequity(6) Real
estate(7)
Infrastructure(8) Hedge
funds

☑

☑

☑

☑

☑

☑

(B) We engage the external manager's
board or investment committee

☑

☑

☑

☑

☑

☑

(C) We reduce exposure with theexternal manager until any nonconformances have been rectiﬁed

☐

☐

☐

☐

☐

☐

(D) We terminate the contract withthe external manager if failings
persist over a (notiﬁed) period oftime and explain the reasons for thetermination

☐

☐

☐

☐

☐

☐

(E) Other, please specify

☐

☐

☐

☐

☐

☐

95

(F) Our organisation does not have aformal escalation process to addressconcerns raised by monitoring

☐

☐

☐

☐

☐

☐

Listed Equity (LE)Pre-investment phase
Materiality analysis
Indicator

Type of indicator

Dependent on

Gateway toDisclosure

Subsection

PRI Principle

LE 1

CORE

OO 10

LE 1.1

PUBLIC

Materiality analysis

1

Does your organisation have a formal investment process to identify material ESG factors across listed equities?
(2) Active – quantitative(A) Yes, we have a formal process
to identify material ESG factors forall of our assets◉(B) Yes, we have a formal process
to identify material ESG factors forthe majority of our assets○(C) Yes, we have a formal process
to identify material ESG factors fora minority of our assets○(D) No, we do not have a formal
process. Our investment
professionals identify material ESG
factors at their own discretion○(E) No, we do not have a formal
process to identify material ESG
factors○

96

IndicatorType of indicator

Dependent on

Gateway toDisclosure

Subsection

PRI Principle

LE 1.1

CORE

LE 1

N/A

PUBLIC

Materiality analysis

1

How does your current investment process incorporate material ESG factors?
(2) Active - Quantitative(A) The investment processincorporates material governancefactors☑

(B) The investment processincorporates material environmental
and social factors☑

(C) The investment processincorporates material ESG factors
beyond our organisation's typicalinvestment time horizon☑

(D) The investment processincorporates the effect of material
ESG factors on revenues andbusiness operations☐

Long-term ESG trend analysis
Indicator

Type ofindicator

DependentonGatewaytoDisclosure

Subsection

PRI
Principle

LE 2

CORE

OO 10

N/A

PUBLIC

Long-term ESG trend
analysis1

Do you continuously monitor a list of identiﬁed long-term ESG trends related to your listed equity assets?
(2) Active – quantitative(A) We monitor long-term ESG
trends for all assets◉

97

(B) We monitor long-term ESG
trends for the majority of assets○(C) We monitor long-term ESG
trends for a minority of assets○(D) We do not continuously
monitor long-term ESG trends in
our investment process○

ESG incorporation
Indicator

Type of indicator

Dependent on

Gateway toDisclosure

Subsection

PRI Principle

LE 3

CORE

OO 10

LE 3.1

PUBLICESG incorporation

1

How does your ﬁnancial modelling and equity valuation process incorporate material ESG risks?
(2) Active – quantitative(A) We incorporate governancerelated risks into ﬁnancial modellingand equity valuations☑

(B) We incorporate environmental
and social risks into ﬁnancial
modelling and equity valuations☑

(C) We incorporate environmental
and social risks related tocompanies' supply chains intoﬁnancial modelling and equity
valuations☑

(D) ESG risk is incorporated intoﬁnancial modelling and equity
valuations at the discretion ofindividual investment decisionmakers, and we do not track thisprocess☐98

(E) We do not incorporate ESG
risks into our ﬁnancial modellingand equity valuations☐

Indicator

Type of indicator

Dependent on

Gateway toDisclosure

Subsection

PRI Principle

LE 3.1

CORE

LE 3

N/A

PUBLICESG incorporation

1

In what proportion of cases do you incorporate the following material ESG risks into your ﬁnancial modelling and equity
valuation process?
(2) Active - Quantitative(A) We incorporate governance-related risks into ﬁnancial modelling and equity
valuations(3) in a minority of cases(B) We incorporate environmental and social risks into ﬁnancial modelling and equity
valuations(3) in a minority of cases(C) We incorporate environmental and social risks related to companies' supply chains
into ﬁnancial modelling and equity valuations(3) in a minority of cases

Assessing ESG performance
Indicator

Type ofindicator

DependentonGatewaytoDisclosure

Subsection

PRI
Principle

LE 4

CORE

OO 10

LE 4.1

PUBLIC

Assessing ESG
performance

1

What information do you incorporate when you assess the ESG performance of companies in your ﬁnancial modelling and equity
valuation process?
(2) Active – quantitative(A) We incorporate information on
current performance across a rangeof ESG metrics☑

99

(B) We incorporate information on
historical performance across a
range of ESG metrics☑

(C) We incorporate information
enabling performance comparison
within a selected peer group acrossa range of ESG metrics☑

(D) We incorporate information on
ESG metrics that may impact orinﬂuence future corporate revenues
and/or proﬁtability☑

(E) We do not incorporate ESG
factors when assessing the ESG
performance of companies in ourﬁnancial modelling or equity
valuation☐

Indicator

Type ofindicator

DependentonGatewaytoDisclosure

Subsection

PRI
Principle

LE 4.1

CORE

LE 4

N/A

PUBLIC

Assessing ESG
performance1

In what proportion of cases do you incorporate the following information when assessing the ESG performance of companies inyour ﬁnancial modelling and equity valuation process?
(2) Active – quantitative(A) We incorporate information on current performance across a range of ESG metrics(3) in a minority of cases(B) We incorporate information on historical performance across a range of ESG
metrics(3) in a minority of cases(C) We incorporate information enabling performance comparison within a selected
peer group across a range of ESG metrics(3) in a minority of cases(D) We incorporate information on ESG metrics that may impact or inﬂuence future
corporate revenues and/or proﬁtability(3) in a minority of cases

100

ESG incorporation in portfolio construction
Indicator

Type ofindicator

DependentonGatewaytoDisclosure

Subsection

PRI
Principle

LE 5

PLUS

OO 10

N/A

PUBLICESG incorporation in portfolio
construction

1

Outline one best practice or innovative example where ESG factors have been incorporated into your equity selection andresearch process.
In the evaluation of ESG factors, we have chosen to focus on those factors that are identiﬁed as ﬁnancially material. In 2017, wedeveloped our in-house ESG metrics for measuring company-level performance on sustainability issues. These scores leverage theSustainability Accounting Standards Board (SASB) framework for identifying material ESG issues for each company based on industry.
These scores are used both to evaluate our funds and to tilt portfolios with explicit ESG objectives away from the lowest scoring
companies and towards high performers.

Indicator

Type ofindicator

DependentonGatewaytoDisclosure

Subsection

PRI
Principle

LE 6

CORE

OO 10

LE 6.1

PUBLICESG incorporation in portfolio
construction

1

How do ESG factors inﬂuence your portfolio construction?
(2) Active – quantitative(A) The selection of individual
assets within our portfolio isinﬂuenced by ESG factors☑

(B) The holding period ofindividual assets within our
portfolio is inﬂuenced by ESG
factors☐(C) The portfolio weighting ofindividual assets within our
portfolio or benchmark is inﬂuenced
by ESG factors☑

101

(D) The allocation of assets acrossmulti-asset portfolios is inﬂuenced
by ESG factors through thestrategic asset allocation process☐(E) Other expressions of conviction(please specify below)☐(F) The portfolio construction or
benchmark selection does not
explicitly include the incorporationof ESG factors☐

Indicator

Type ofindicator

DependentonGatewaytoDisclosure

Subsection

PRI
Principle

LE 6.1

CORE

LE 6

N/A

PUBLICESG incorporation in portfolio
construction

1

In what proportion of cases did ESG factors inﬂuence your portfolio construction?
(2) Active – quantitative(A) The selection of individual assets within our portfolio is inﬂuenced by ESG factors(3) in a minority of cases(C) The portfolio weighting of individual assets within our portfolio or benchmark is
inﬂuenced by ESG factors(3) in a minority of cases

102IndicatorType ofindicator

DependentonGatewaytoDisclosure

Subsection

PRI
Principle

LE 7

PLUS

OO 10

N/A

PUBLICESG incorporation in portfolio
construction

1

Please provide two examples of how ESG factors have inﬂuenced weightings and tilts in either passive or active listed equity.
Provide examples below:(A) Example 1:

In our Decarbonization 2.0 strategy, we will modify security
weights based on Material ESG scores--potentially increasing
allocations to securities with high Material ESG scores andpotentially decreasing allocations to securities with low
Material ESG scores(B) Example 2:

For our commingled Europe and Australia funds, we haveexcluded tobacco and controversial weapons securities.

ESG risk management
Indicator

Type of indicator

Dependent on

Gateway toDisclosure

Subsection

PRI Principle

LE 8

CORE

OO 6.1 LE

N/A

PUBLICESG risk management

1

What compliance processes do you have in place to ensure that your listed equity assets sub ject to negative exclusionary screens
meet the screening criteria?
☐ (A) We have an independent committee that oversees the screening implementation process, but only for our
ESG/sustainability labelled funds that are sub ject to negative exclusionary screening☐ (B) We have an independent committee that oversees the screening implementation process for all of our listed equity assetsthat are sub ject to negative exclusionary screening☐ (C) We have an independent committee that veriﬁes that we have correctly implemented pre-trade checks in our internal
systems to ensure no execution is possible without their pre-clearance☑ (D) Other, please specify:

Many layers of internal controls exist to oversee the screening process including an automated strategy implementation processes,
monthly portfolio manager certiﬁcation, annual performance reviews, exclusion committees, audits by compliance department, and othersystematic checks.
In addition, external audits are undertaken of funds subject to exclusions; however, practices vary across the many regions in which we
operate.

☐ (E) We do not have compliance processes in place to ensure that we meet our stated negative exclusionary screens

103

Post-investment phase
Indicator

Type of indicator

Dependent on

Gateway toDisclosure

Subsection

PRI Principle

LE 9

CORE

OO 10

N/A

PUBLICESG risk management

1

Do your regular reviews incorporate ESG risks?
(2) Active – quantitative(A) Our regular reviews include
quantitative information onmaterial ESG risks speciﬁc toindividual listed equities☐(B) Our regular reviews include
aggregated quantitative information
on material ESG risks at a fund
level

☑

(C) Our regular reviews only
highlight fund holdings where ESG
ratings have changed☐(D) We do not conduct regularreviews. Risk reviews of ESG factors
are conducted at the discretion of
the individual fund manager andvary in frequency☐(E) We do not conduct reviews☐

104IndicatorType of indicator

Dependent on

Gateway toDisclosure

Subsection

PRI Principle

LE 10

CORE

OO 10

N/A

PUBLICESG risk management

1

Do you regularly identify and incorporate ESG incidents into the investment process for your listed equity assets?
(2) Active – quantitative(A) Yes, we have a formal process
in place for regularly identifying
and incorporating ESG incidents
into all of our investment decisions○(B) Yes, we have a formal process
in place for regularly identifying
and incorporating ESG incidents
into the majority of our investment
decisions○(C) Yes, we have a formal process
in place for regularly identifying
and incorporating ESG incidents
into a minority of our investment
decisions◉(D) Yes, we have an ad hoc process
in place for identifying andincorporating ESG incidents○(E) Other○(F) We currently do not have aprocess in place for regularly
identifying and incorporating ESG
incidents into our investment
decision-making○

105

Reporting/Disclosure
Sharing ESG information with stakeholders
Indicator

Type ofindicator

DependentonGatewaytoDisclosure

Subsection

PRI
Principle

LE 13

CORE

OO 6 LE

N/A

PUBLIC

Sharing ESG information withstakeholders

6

How do you ensure that clients and/or beneﬁciaries understand ESG screens and their implications?

(1) for all of ourlisted equity
assets sub ject to
ESG screens(2) for the
majority of ourlisted equity
assets sub ject to
ESG screens(3) for aminority of ourlisted equity
assets sub ject to
ESG screens(4) for none of ourassets sub ject to
ESG screens(A) We publish a list of ESG screensand share it on a publicly accessible
platform such as a website or
through fund documentation

◉

○

○

○

(B) We publish any changes in ESG
screens and share them on a publicly
accessible platform such as a website
or through fund documentation

◉

○

○

○

(C) We outline any implications of
ESG screens, such as deviation froma benchmark or impact on sector
weightings, to clients and/or
beneﬁciaries

◉

○

○

○

106

IndicatorType ofindicator

DependentonGatewaytoDisclosure

Subsection

PRI
Principle

LE 14

CORE

OO 10

N/A

PUBLIC

Sharing ESG information withstakeholders

6

What ESG information is covered in your regular reporting to stakeholders such as clients or beneﬁciaries?
(2) Active – quantitative(A) Our regular stakeholder reporting includes qualitative examples of engagement
and/or ESG incorporation

3) In a minority of our stakeholder
reporting(B) Our regular stakeholder reporting includes quantitative ESG engagement data

3) In a minority of our stakeholder
reporting(C) Our regular stakeholder reporting includes quantitative ESG incorporation data

2) In the majority of our regularstakeholder reporting

Stewardship
Voting policy
Indicator

Type of indicator

Dependent on

Gateway toDisclosure

Subsection

PRI Principle

LE 15

CORE

OO 9 LELE 15.1, LE 16

PUBLIC

Voting policy

2

Does your organisation have a publicly available (proxy) voting policy? (The policy may be a standalone policy, part of a
stewardship policy or incorporated into a wider RI policy.)◉ (A) Yes, we have a publicly available (proxy) voting policy Add link(s):https://russellinvestments.com/-/media/ﬁles/us/corporate/russell-investments-proxy-voting-guidelines.pdf?
la=en&hash=83A27EE4ECF45299CB2D0CB04D847E6F753441BD○ (B) Yes, we have a (proxy) voting policy, but it is not publicly available○ (C) No, we do not have a (proxy) voting policy

107

IndicatorType of indicator

Dependent on

Gateway toDisclosure

Subsection

PRI Principle

LE 15.1

CORE

OO 9 LE, LE 15

N/A

PUBLIC

Voting policy

2

What percentage of your listed equity assets does your (proxy) voting policy cover?
(A) Actively managed listed equity covered by our voting policy(12) 100%

Indicator

Type of indicator

Dependent on

Gateway toDisclosure

Subsection

PRI Principle

LE 16

CORE

LE 15

N/A

PUBLIC

Voting policy

2

Does your organisation's policy on (proxy) voting cover speciﬁc ESG factors?
☑ (A) Our policy includes voting guidelines on speciﬁc governance factors Describe:

The ma jority of Russell Investments’ Proxy Voting Guidelines support governance structures that ensure that management and board
members maintain independence, objectivity, and act in the best interest of shareholders. The guidelines provide speciﬁc direction on
Director Elections, addressing issues such as overboarding and diversity. Section VII of our guidelines is dedicated entirely to Corporate
Governance, and includes our policies on speciﬁc issues such as proxy access, golden coﬃn payments, and more. Further details can befound in our Proxy Voting Guidelines.

☑ (B) Our policy includes voting guidelines on speciﬁc environmental factors Describe:

Section XIV of our proxy voting guidelines refers to environmental issues which are at risk of negatively impacting shareholder value.
Russell Investments does not apply a blanket policy to environmental issues, and so proposals that fall into this category are, in mostcases, directed to the Proxy Voting and Engagement Committee for individual review. Environmental issues which may be directed to
the Committee per this section include ESG reporting, water issues, calls for the reduction of greenhouse gas emission, requests that acompany adopt a comprehensive recycling strategy or invest in renewable energy sources, among others. Further details can be found in
our Proxy Voting Guidelines.

☑ (C) Our policy includes voting guidelines on speciﬁc social factors Describe:

Section XIV of our proxy voting guidelines also covers social issues which are at risk of negatively impacting shareholder value, throughﬁnancial or reputational hardship. As with environmental proposals, many social issue votes are frequently referred to the Proxy Voting
committee for assessment. The guidelines speciﬁcally address issues such as workplace safety, product safety, diversity and equal
opportunity employment, as well as political and human rights issues. Further details can be found in our Proxy Voting Guidelines.

☐ (D) Our policy is high-level and does not cover speciﬁc ESG factors Describe:

108

Alignment & effectivenessIndicator

Type of indicator

Dependent on

Gateway toDisclosure

Subsection

PRI Principle

LE 17

CORE

OO 9 LE

N/A

PUBLICAlignment & effectiveness2

When you use external service providers to give voting recommendations, how do you ensure that those recommendations are
consistent with your organisation's (proxy) voting policy?
(A) We review service providers' controversial and high-proﬁle voting recommendations
before voting is executed(1) in all cases(B) Before voting is executed, we review service providers' voting recommendations
where the application of our voting policy is unclear(1) in all cases

Security lending policy
Indicator

Type ofindicator

DependentonGateway toDisclosure

Subsection

PRI Principle

LE 18

CORE

OO 9 LELE 18.1, LE
18.2

PUBLIC

Security lending
policy2

Does your organisation have a public policy that states how voting is addressed in your securities lending programme? (Thepolicy may be a standalone guideline or part of a wider RI or stewardship policy.)○ (A) We have a public policy to address voting in our securities lending programme. Add link(s):◉ (B) We have a policy to address voting in our securities lending programme, but it is not publicly available○ (C) We rely on the policy of our service provider(s)○ (D) We do not have a policy to address voting in our securities lending programme○ (E) Not applicable, we do not have a securities lending programme109

IndicatorType of indicator

Dependent on

Gateway toDisclosure

Subsection

PRI Principle

LE 18.1

CORE

LE 18

N/A

PUBLIC

Security lending policy

2

How is voting addressed in your securities lending programme?
◉ (A) We recall all securities for voting on all ballot items○ (B) We always recall all holdings in a company for voting on ballot items deemed important (e.g. in line with speciﬁc criteria)○ (C) We always recall some securities so that we can vote on their ballot items (e.g. in line with speciﬁc criteria)○ (D) We maintain some holdings so that we can vote at any time
○ (E) We recall some securities on an ad hoc basis so that we can vote on their ballot items○ (F) We empower our securities lending agent to decide when to recall securities for voting purposes○ (G) Other, please specify:○ (H) We do not recall our securities for voting purposes
Indicator

Type of indicator

Dependent on

Gateway toDisclosure

Subsection

PRI Principle

LE 18.2

CORE

LE 18

N/A

PUBLIC

Security lending policy

2

What exclusions do you apply to your organisation's securities lending programme?
☐ (A) We do not lend out shares of companies that we are engaging with either individually or as a lead or support investor incollaborative engagements☐ (B) We do not lend out shares of companies if we own more than a certain percentage of them
☐ (C) We do not lend out shares of companies in jurisdictions that do not ban naked short selling☐ (D) We never lend out all our shares of a company to ensure that we always keep voting rights in-house☑ (E) Other, please specify:
Russell Investments recalls all shares of a company if Russell Investments owns more than 2% or in the case of a potential or deﬁnite
pending merger or acquisition. The shares are restricted from lending until the record date has passed.

☐ (F) We do not exclude any particular companies from our securities lending programme110Shareholder resolutions
Indicator

Type of indicator

Dependent on

Gateway toDisclosure

Subsection

PRI Principle

LE 19

CORE

OO 9 LE

N/A

PUBLIC

Shareholder resolutions

2

Which of the following best describes your decision-making approach regarding shareholder resolutions, or that of your service
provider(s) if decision-making is delegated to them?
◉ (A) In the majority of cases, we support resolutions that, if passed, are expected to advance progress on the underlying ESG
factors or on our stewardship priorities○ (B) In the majority of cases, we support resolutions that, if passed, are expected to advance progress on the underlying ESG
factors but only if the investee company has not already committed publicly to the action requested in the proposal○ (C) In the majority of cases, we only support shareholder resolutions as an escalation tactic when other avenues forengagement with the investee company have not achieved suﬃcient progress○ (D) In the majority of cases, we support the recommendations of investee company management by default○ (E) In the majority of cases, we do not vote on shareholder resolutions

Pre-declaration of votes
Indicator

Type of indicator

Dependent on

Gateway toDisclosure

Subsection

PRI Principle

LE 20

CORE

OO 9 LE

N/A

PUBLIC

Pre-declaration of votes

2

How did your organisation or your service provider(s) pre-declare votes prior to AGMs/EGMs?
☐ (A) We pre-declared our voting intentions publicly through the PRI's vote declaration system☐ (B) We pre-declared our voting intentions publicly (e.g. through our own website) Link to public disclosure:☐ (C) We pre-declared our voting intentions publicly through the PRI's vote declaration system, including the rationale for our(proxy) voting decisions where we planned to vote against management proposals or abstain☐ (D) We pre-declared our voting intentions publicly, including the rationale for our (proxy) voting decisions where we planned
to vote against management proposals or abstain Link to public disclosure:☐ (E) Prior to the AGM/EGM, we privately communicated our voting decision to investee companies in cases where we planned
to vote against management proposals or abstain☑ (F) We did not privately or publicly communicate our voting intentions☐ (G) We did not cast any (proxy) votes during the reporting year111

Voting disclosure post AGM/EGM
Indicator

Type ofindicator

DependentonGatewaytoDisclosure

Subsection

PRI
Principle

LE 21

CORE

OO 9 LELE 21.1

PUBLIC

Voting disclosure post
AGM/EGM2

Do you publicly report your (proxy) voting decisions, or those made on your behalf by your service provider(s), in a central
source?
○ (A) Yes, for >95% of (proxy) votes Link:◉ (B) Yes, for the majority of (proxy) votes Link:

13
https://viewpoint.glasslewis.com/WD/?siteId=RussellInd ; https://viewpoint.glasslewis.com/WD/?siteId=RussellInst ;https://viewpoint.glasslewis.com/WD/?siteId=RussellAus ; https://viewpoint.glasslewis.com/WD/?siteId=RussellCan ;○ (C) Yes, for a minority of (proxy) votes 1) Add link and 2) Explain why you only publicly disclose a minority of (proxy) voting
decisions:○ (D) No, we do not publicly report our (proxy) voting decisions Explain why you do not publicly report your (proxy) voting
decisions:Indicator

Type ofindicator

DependentonGatewaytoDisclosure

Subsection

PRI
Principle

LE 21.1

CORE

LE 21

N/A

PUBLIC

Voting disclosure post
AGM/EGM2

In the majority of cases, how soon after an investee's AGM/EGM do you publish your voting decisions?
○ (A) Within one month of the AGM/EGM◉ (B) Within three months of the AGM/EGM○ (C) Within six months of the AGM/EGM○ (D) Within one year of the AGM/EGM○ (E) More than one year after the AGM/EGM

112

IndicatorType ofindicator

DependentonGatewaytoDisclosure

Subsection

PRI
Principle

LE 22

CORE

OO 9 LELE 22.1

PUBLIC

Voting disclosure post
AGM/EGM2

Did your organisation and/or the service provider(s) acting on your behalf communicate the rationale for your voting decisions?
☑ (A) In cases where we voted against management recommendations or abstained, the rationale was provided privately to thecompany☐ (B) In cases where we voted against management recommendations or abstained, the rationale was disclosed publicly☐ (C) In cases where we voted against management recommendations or abstained, we did not communicate the rationale☐ (D) We did not vote against management or abstain
Indicator

Type ofindicator

DependentonGatewaytoDisclosure

Subsection

PRI
Principle

LE 22.1

CORE

LE 22

N/A

PUBLIC

Voting disclosure post
AGM/EGM

2

Indicate the proportion of votes where you and/or the service provider(s) acting on your behalf communicated the rationale foryour voting decisions.
(A) In cases where we voted against management recommendations or abstained, therationale was provided privately to the company(1) 1–10%

Indicator

Type ofindicator

DependentonGatewaytoDisclosure

Subsection

PRI
Principle

LE 23

CORE

OO 9 LELE 23.1

PUBLIC

Voting disclosure post
AGM/EGM2, 5

Did your organisation and/or the service provider(s) acting on your behalf communicate the rationale for your voting decisions
when voting against a shareholder resolution proposed/ﬁled by a PRI signatory?
☐ (A) In cases where we voted against a shareholder resolution proposed/ﬁled by a PRI signatory, the rationale was disclosed
publicly☑ (B) In cases where we voted against a shareholder resolution proposed/ﬁled by a PRI signatory, the rationale was notdisclosed publicly☐ (C) We did not vote against any shareholder resolution proposed/ﬁled by a PRI signatory

113

Alignment & effectivenessIndicator

Type of indicator

Dependent on

Gateway toDisclosure

Subsection

PRI Principle

LE 24

PLUS

OO 9 LE

N/A

PUBLICAlignment & effectiveness2

How are you contributing to the integrity of the end-to-end voting chain and conﬁrmation process?
In 2020, to ensure that our practices are aligned with best practice principles, the Proxy Voting and Engagement Committee instituted
a new internal audit process to ensure that our proxy service provider accurately casts votes in accordance with our guidelines.
Although this internal audit process was already in place for certain funds due to regional regulatory requirements, the Proxy Voting
and Engagement Committee has made the decision, alongside our internal risk team, to expand the audit process to include all funds inall jurisdictions. This level of oversight helps to hold our proxy service provider accountable for executing the services they provide fully
and accurately.

Sustainability Outcomes (SO)Set targets on sustainability outcomes
Outcome objectives
Indicator

Type of indicator

Dependent on

Gateway toDisclosure

Subsection

PRI Principle

SO 1

PLUS

ISP 45

SO 1.1, SO 2

PUBLIC

Outcome ob jectives1

Has your organisation chosen to shape any speciﬁc sustainability outcomes?
◉ (A) Yes
○ (B) No114

IndicatorType of indicator

Dependent on

Gateway toDisclosure

Subsection

PRI Principle

SO 2

PLUS

SO 1

SO 3

PUBLIC

Outcome ob jectives

1

Please list up to 10 of the speciﬁc sustainability outcomes that your organisation has chosen to shape.
Sustainability outcomes(A) Sustainability Outcome #1

Net zeroTarget-setting process
Indicator

Type of indicator

Dependent on

Gateway toDisclosure

Subsection

PRI Principle

SO 3

PLUS

SO 2

SO 3.1

PUBLIC

Target-setting process

1

Have you set any targets for your sustainability outcomes? Indicate how many targets you have set for each sustainability
outcome.
(A) Sustainability Outcome #1:(2) One target

Indicator

Type ofindicator

DependentonGateway toDisclosure

Subsection

PRI
Principle

SO 3.1PLUS

SO 3

Multiple, seeguidance

PUBLIC

Target-setting
process

1

For each sustainability outcome, name and provide a brief description of up to two of your targets and list the metrics or key
performance indicators (KPIs) associated with them, the targets' deadlines and the percentage of your assets under management
to which the targets apply.

(A1) Sustainability Outcome #1:(Target 1)

Target name

Target description

Net zero carbon emissions by 2050

To be developed over next 12 months

KPIs/metrics

Target deadline: Year

115

(A1) Sustainability Outcome #1:(Target 1)

Net zero emissions in AUM

2050

Coverage: % of assets under management(A1) Sustainability Outcome #1: (Target 1)

100

Indicator

Type of indicator

Dependent on

Gateway toDisclosure

Subsection

PRI Principle

SO 4

PLUS

SO 3.1

N/A

PUBLIC

Target-setting process1

Which global goals (or other references) did your organisation use to determine your sustainability outcomes targets? Explain
whether you have derived your target from global goals, e.g. by translating a global goal into a target at the national, regional,
sub-national, sectoral or sub-sectoral level. Alternatively, explain why you have set your target independently from global goals.
Global goals/references(A1) Sustainability Outcome #1: (Target 1)

As a leading global investment solutions partner dedicated to
improving people's ﬁnancial security, Russell Investments
understands the importance of being a responsible investor
and an active steward of our clients’ capital. But this
responsibility and opportunity extends beyond the clientsteward relationship: our investment approach brings theworld’s leading managers and strategies together into
diversiﬁed portfolios, and as a result, we occupy a uniquepoint of inﬂuence between our clients, investment manager
partners, standards bodies, and corporate entities.

116

Tracking progress
Indicator

Type of indicator

Dependent on

Gateway toDisclosure

Subsection

PRI Principle

SO 5

PLUS

SO 3.1

SO 5.1, SO 5.2

PUBLIC

Tracking progress

1

Does your organisation track intermediate performance and progress against your sustainability outcomes targets?
(A1) Sustainability Outcome #1: (Target 1)(1) Yes

Indicator

Type of indicator

Dependent on

Gateway toDisclosure

Subsection

PRI Principle

SO 5.1

PLUS

SO 5

N/A

PUBLIC

Tracking progress1

How does your organisation track intermediate performance and progress against your sustainability outcomes targets?
Please describe below:
Russell Investments publishes an annual Proxy andEngagement Report that we share publicly on our webpage.

(A1) Sustainability Outcome #1: (Target 1)

Indicator

Type of indicator

Dependent on

Gateway toDisclosure

Subsection

PRI Principle

SO 5.2

PLUS

SO 5

N/A

PUBLIC

Tracking progress

1

Describe any qualitative or quantitative progress achieved during the reporting year against your sustainability outcomes targets.

(A1) Sustainability Outcome #1:(Target 1)(1) Qualitative progress(2) Quantitative progress

We are developing targets over the
next 12 months for Net Zero.

We are developing targets over the next
12 months for Net Zero.

117

IndicatorType of indicator

Dependent on

Gateway toDisclosure

Subsection

PRI Principle

SO 6

PLUS

SO 3.1

SO 6.1

PUBLIC

Tracking progress2

Despite your organisation’s efforts to make progress on your sustainability outcomes, there may be stakeholders who have been
negatively affected by your organisation’s activities. For each of your sustainability outcomes, indicate whether your organisation
ensures that stakeholders who have been negatively affected are able to seek an effective remedy.
(A) Sustainability Outcome #1:(1) Yes

Indicator

Type of indicator

Dependent on

Gateway toDisclosure

Subsection

PRI Principle

SO 6.1

PLUS

SO 6

N/A

PUBLIC

Tracking progress2

How does your organisation ensure that stakeholders negatively affected by your activities are able to seek an effective remedy?
Please describe below:(A) Sustainability Outcome #1:

Russell Investments will be setting targets over the next 12months for Net Zero.

118

Investors’ individual and collective actions shapeoutcomes
Levers for shaping outcomes
Indicator

Type ofindicator

DependentonGateway toDisclosure

Subsection

PRI
Principle

SO 7

PLUS

SO 3.1

SO 7.1 - SO
22,

PUBLIC

Levers for shaping
outcomes

1, 2, 5Which levers did your organisation or service providers/external investment managers acting on your behalf use to make progresson your sustainability outcomes during the reporting year?
(1) Individually(2) With other investors or stakeholders(A) Asset allocation☐☐(B) Investee engagement including
voting☐☐(C) Systemic stewardship including
policy engagement☐☐(D) None of the above

☑

☑

119

Global stakeholders collaborate to achieve outcomes
Tracking progress against global goals
Indicator

Type ofindicator

DependentonGatewaytoDisclosure

Subsection

PRI
Principle

SO 23

PLUS

SO 3.1

N/A

PUBLIC

Tracking progress against global
goals

4

Does your organisation engage with standard setters, reporting bodies or similar organisations to help track and communicate
progress against global sustainability goals?
○ (A) Yes. Please describe:◉ (B) No. Please describe why not:Russell Investments is developing its strategy for achieving net zero over the next 12 months.

Indicator

Type ofindicator

DependentonGatewaytoDisclosure

Subsection

PRI
Principle

SO 24

PLUS

SO 3.1

N/A

PUBLIC

Tracking progress against global
goals

4

Does your organisation contribute to public goods (such as research) or public discourse (such as media coverage) to makeprogress on global sustainability goals?
◉ (A) Yes. Please describe:

Our support for net zero is publicly disclosed.

○ (B) No. Please describe why not:120