September 2023

Responsible Investing

Controversial weapons policy

The production and use of certain weapons have been deemed unacceptable under international
conventions and even illegal within certain jurisdictions because they may cause severe harm tocivilians during and after the conflicts and generate significant long term health and safety effects on
the civilian population.
These controversial weapons regulated by international conventions are anti-personnel landmines, cluster munitions, chemical,
biological and nuclear weapons (collectively referred to as “Controversial Weapons”).
Since 2008, AXA IM has implemented an exclusion policy for investment in companies involved in anti-personnel landmines andcluster bombs. This exclusion policy has been extended to include those companies involved in depleted uranium, chemical andbiological weapons and those companies in breach with the Non-proliferation Treaty for nuclear weapons. Definitions of theControversial Weapons used by AXA IM to identify the Excluded Companies are those stated in the international conventions
listed below:• The Ottawa Convention on Anti-Personnel Landmines, which entered into force on 1 March 1999;• The Oslo Convention on Cluster Munitions, which entered into force on 1 August 2010;• The Convention on the Prohibition of the Development, Production and Stockpiling of Bacteriological and Toxin
Weapons and on their Destruction that entered into force on 26 March 1975;• The Convention on the Prohibition of the Development, Production, Stockpiling and Use of Chemical Weapons and on
their Destruction (CWC), which entered into force in 1997;• The Treaty on the Non-Proliferation of Nuclear Weapons (NPT), rigorously controlled by the United Nations thatentered into force on 5 March 1975;• The Council Regulation (EU) 2018/1542 of 15 October 2018 concerning restrictive measures against the proliferation
and use of chemical weapons.

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AXA IM considers that investment in companies involved in Controversial Weapons activities (“Excluded Companies”) or
provisions to such companies should be avoided. This policy defines a set of rules and procedures which aim to address thisprinciple within the AXA IM Group.
In addition, AXA IM will not develop any business with the Excluded Companies.

Excluded companies
Sector / Area-

Controversialweapons---

Exclusion criteria
Approach and frequency of the update
Companies that produce, use, store,
The list of Excluded Companies covers all
trade, or ensure the maintenance of, companies worldwide, be they statetransport or financing of Controversial owned or private companies, listed orWeapons including components
unlisted companies.
specifically designed for those types ofControversial Weapons (customised
Affiliates1 of such Excluded Companies arecomponents).
not excluded unless involved in theCompanies that provide support,production, use or distribution ofresearch or technology dedicated only Controversial Weapons.
to those Controversial Weapons
Companies that breach the Treaty on The exclusion list is updated on a yearly
the Non-proliferation Treaty ofbasis unless a specific event requires anNuclear Weapons.
intermediate revision or a delay in theCompanies that own 50% or more of publication of data requires to postpone
an Excluded Company.
the update.

Sources

We rely on external
providers to prepare
an initial list ofissuers in scope.
The list is reviewed
by our internal
governance bodies.

Scope of the policy
Financial instruments
The policy applies to all single-name financial instruments issued by the Excluded Companies or offering exposure to Excluded
Companies.
Portfolios
The policy applies in principle to all portfolios under AXA IM’s management, including dedicated fund and third-party mandates,
unless the client has given different instructions for its mandate in line with local regulation 2.
For index funds under AXA IM’s management, the policy applies to the extent the objective of the fund is not compromised. AXA
IM will support any initiative to promote the use of indices which do not comprise any Excluded Companies.
The policy applies to direct product investments, overall with no look-through except when local laws or regulations require todo so.
Entities
This policy applies to AXA IM and all its affiliates worldwide, to joint ventures when AXA IM’s stake is 50% or higher, and to funds
for which the management is delegated to one of our joint ventures.

1 For the purpose of this policy, the term “affiliate” shall mean any entity, individual, firm or corporation, directly or indirectly, through one

or more intermediaries, controlling or controlled by Excluded Companies.
2Regarding the specific exclusion of companies involved in depleted uranium weapons, while these weapons are not banned byinternational treaties, they might be prohibited in some countries under national law (such as, but not limited to, Belgium or Ireland at thedate of issuance of such policy). In this context, clients have the possibility to opt out solely for assets related to depleted uranium provided
that it is compliant with the client’s product applicable regulations.

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Implementation
If the application of this standard dictates divestments, portfolio managers shall disinvest as soon as possible on a best-effort
basis taking into account the technical implementation timing and the portfolio impacts based on market conditions, liquidity
and portfolio construction constraints. In practice, some targeted instruments could remain in the funds or mandates for aperiod if deemed in the best interest of their clients and provided that it is compliant with the applicable Laws; however, thoseholdings cannot be increased3. For certain alternative products such as Collateralized Loan Obligations (“CLOs”), Mutual
Securitization Funds (“FCT” in French), closed-ended alternative funds and other alternative products, if the divestment is
considered impossible, such holdings in portfolio could be kept until maturity following an internal validation process.
The exclusion lists are prepared using information from external data providers, and although a qualitative review is performed,
AXA IM is therefore not responsible for the accuracy of this data.
The implementation of this policy is subject to compliance with asset management local laws or regulations; therefore, somespecific alternative implementation mechanisms of this policy may be put in place locally. In the EU, the implementation of thispolicy is part of the compliance with the EU Sustainable Finance Disclosure Regulation’s (SFDR) requirements as it constitutes
AXA IM’s approach to consider sustainable investments for the ‘Do No Significantly Harm’ (DNSH) criteria (i.e., applicable toArticle 8 and Article 9 funds). Thus, if the application of this standard dictates divestments, portfolio managers shall disinvest for
their product to be classified Article 8 or Article 9, following the abovementioned implementation process.

3 Such tolerance could be applied, for example in relation to strategies with accounting objectives (e.g., ‘buy & maintain’ strategies), or forconcentrated strategies with appropriate validation from oversight functions.
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