Global Responsible
Investment Policy

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Amundi - Global Responsible Investment Policy

Purposeand Scope
PURPOSESCOPE

The document details how Amundi implements
its commitment to act as a responsible asset
manager in its investments and operations. It
also outlines the key building blocks of Amundi’s
Global Responsible Investment Policy and its
strategic orientations, which are under direct
responsibility of Amundi’s ESG and Climate
Strategic Committee, chaired by Amundi’s CEO.

Unless specified in the relevant sections of
the documents (for instance in the MinimumStandards and Exclusion Policy section), theset of commitments and processes describedherein apply to, and on behalf of, all assets
managed by Amundi Group entities.
The following affiliates and associated entities of
the Amundi Group do not apply, or not to its full
extent, Amundi’s Global Responsible Investment
Policy (please refer to their respective policy
documents for further details):• ABC-CA Fund Management Company*• Amundi-ACBA Asset Management*• KBI Global Investors Ltd• NH-Amundi Asset Management*• Pioneer Family of US mutual funds, retailseparately managed accounts, and certain
pooled vehicles advised by Amundi AssetManagement US, Inc.
• SBI Funds Management Limited*• Wafa Gestion*

Last update: November 2023

*ABC-CA Fund Management Company, Amundi-ACBA Asset Management, NH-Amundi Asset Management, SBI Funds
Management Limited and Wafa Gestion are joint ventures of Amundi.

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Amundi - Global Responsible Investment Policy

Contents
02 Purpose and scope
responsible
04 Amundi’s
commitments and ambitions

08 A dedicated organisation– Specialised resources– Dedicated governance

11 ESG analysis and integration– ESG analysis for corporate issuers

26 Engagement policy– Measuring and monitoring
engagement progress– Engagement escalation

29 Reporting and transparency– Responsible investment assets
under management reporting– ESG product policies– Labels and transparency of
information– EU regulatory information– ESG analysis for sovereign issuers– Other types of instruments or
issuers– Integrating ESG into our analysis
and investment processes– Responsible external managers
selection– Responsible external fundselection– Disclosure on the use of raw ESG
data, third-party ESG scores and
ESG data productsStandards
18 Minimum
and Exclusion Policy– Normative exclusions linked tointernational conventions– Sector policies– Human Rights Policy– Biodiversity & Ecosystem Services
Policythe asset
33 Advancing
management industry– Active participation in market
bodies– Academic support

35 Appendix– Exclusion policy scope of
application– A long-standing player in ESG
integration

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Amundi - Global Responsible Investment Policy

Amundi’s
responsible
commitments andambitions
Since its creation in 2010, Amundi has made responsible investment
one of its founding pillars. Responsible investing is one of our corevalues and an essential component of our investment managment
approach. Amundi is a subsidiary of Crédit Agricole (CA), France's
largest bank and insurer. Founded by members of farm unions morethan a century ago, CA has evolved into a recognized financial
institution.
Aligned with our parent company’s purpose,and our raison d’être “being a trusted partner
working every day in the interest of its clientsand society” our goal is to deliver long-termvalue for our clients while being mindful ofthe societal and environmental challenges that
impact both our clients and society.
Amundi’scommitment
toresponsible
investment relies on three convictions:➊ The integration of Environmental, Socialand Governance (ESG) criteria in investment
decisions is a driver of long-term financial
performance;➋ Economic and financial actors carry,
alongside governments and consumers, a
responsibility towards society;➌ The acceleration of our ESG ambition is thefirst lever of growth for Amundi globally.

We reflect our commitment and convictions in
our investment management activities, in thedevelopment of our investment solutions range,
and the advisory capabilities and services wedeploy to support our clients.
We embrace the concept of “double materiality”
around which we build our proprietary ESG
analysis and rating methodology, as we
believe both sets of criteria are material when
making investment decisions in the interestsof our beneficiaries, with the aim to generate
sustainable returns1. This means that our ESG
analysis aims at not only assessing the way
ESG factors can materially impact the value ofcompanies, but also how companies can impact
the environment and social matters or humanrights2.

1. Sustainable returns entail the objective of generating sustainable profits combined with high standards of risk
management
2. For specific information on how these ratings and analysis are integrated in the investment decisions of specificinvestment strategies please refer to our product specific disclosure.

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Amundi - Global Responsible Investment Policy

Aspiring to be theleading global
responsible asset
manager
We believe that long-term value creation andsustainable return generation go beyond shortterm financial performance. This conviction has
led us to integrate in our investment philosophy
and practices major sustainability factors (suchas climate change, natural capital preservationand social cohesion). We acknowledge that oursustainability journey is part of a collective effort
made by businesses to contribute to addressingthese issues, and efficiently allocate capital forthe future. Our role in raising standards as aninvestor, but also in terms of ESG performanceof the companies in which we invest in, is a key
part of this contribution.
Being a long-term responsible investor alsochanges our global vision on risk. Amundi
understands that risk is multi-faceted andoperatesoverdifferent
time
horizons.
Nevertheless, we believe that investing for the
long-term is an advantage. Our investment
teams look beyond market risk, and take into
account credit, liquidity, and reputationalrisks, as well as ESG risks generated by anissuer’s activities. They are supported byan independent Risk Department, and an
independent Responsible Investment businessline that accesses specialised research and canprovide its own in-depth analysis of ESG risks
likely to impact portfolios.
In 2021, Amundi completed its first three-year
ESG Action Plan, which aimed to establish an
unprecedented level of ESG integration3 within
its investment activities and throughout theorganization. These ambitions translated into:

Setting ESG performance
objectives for 100% of ouractively managed open-ended
funds4This first objective translated and implemented
our conviction that the integration of ESG
criteria into research and investment decisions
may be key drivers of sustainable return
generation and long-term value creation. Setting
a 100% objective enabled us to “mainstream”
ESG integration and establish a baseline forsystematic ESG integration across Amundi’s
products. As a result, actively managed openended portfolios that are in-scope aim to meet
an ESG performance objective supporting
the strategy’s financial objective, in addition
to any other relevant sustainable investment
characteristics or objectives described in theinvestment policy.

Systematically considering
ESG factors in our dialogue
with investee companies, via
our engagement and voting
activities5
Amundi sees the transition towards a sustainable
and inclusive low carbon economy as afundamental long-term business opportunity
for leading companies and economic actors
and a risk for laggards. As an asset manager,
we believe that carrying out active dialogue
with our investee companies to positively
influence their behaviours and activities will
enable us to deliver real impacts and outcomesalongside sustainable returns. This is the reason
why engagement and voting are key pillars ofAmundi’s Global Responsible Investment policy.

3. The explicit and systematic inclusion of ESG issues in investment analysis and investment decisions (Principles for
Responsible Investment – PRI).
4. Refer to “Purpose and Scope” on page 2 for out or partially out of scope affiliates and associated entities of the AmundiGroup. For in scope entities, see “ESG Product Policies” section. Please review funds’ offering documents for complete
information on responsible investment characteristics.
5. Refer to “Purpose and Scope” on page 2 for out or partially out of scope affiliates and associated entities of the AmundiGroup. For in-scope entities, institutional clients may choose alternative proxy voting policies.

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Supporting transitions
Tailoring our approach toacross sectors and across client needs, reporting
geographies
openly and transparently
Amundi’s approach to ESG and responsible
investing is fundamentally best-in-class bydesign, universal by ambition, and grounded inreality by necessity.
Our ESG analysis & scoring methodology
is designed to enable comparison between
economic actors regarding their ESG practices
within a given sector, distinguishing best andworst ESG practices at sector level utilizing
third party and in-house research to promotewhat we believe are best practices across theentire economy. Not only does it enable us toselect companies based on ESG criteria relevant
for their sectors but it also provides a criticalreferential whenever we engage companies andother issuers on ESG issues.
While supporting the most advanced players
and projects with already transitioned businessmodels remains key, we believe supporting thetransition for the rest of the economy is also
critical to achieve a system-wide change. Inthat respect, responsible investment strategies
promoting best practices in geographies or
sectors that have not yet transitioned can play a
determining role.
Acting responsibly, Amundi strives to manage
industry-leading investment solutions andprovide services and advices which we believe
best answer to the investment needs andprofiles of our clients while taking into accounttheir sustainability preferences. This requires
us to be transparent on the trade-offs andcomparative benefits of certain responsible
investing approaches versus others.

We recognise the responsibility placed in ourhands when granted investment powers andplace fiduciary duty at the core of our action.
We work to deliver on that duty by investing andacting consistently with the long-term interestsof our clients at heart. We believe that our proactive stewardship framework and responsible
investing approach can deliver meaningfulchange and add value over a long-term horizon.
However, in some areas, it could take longer and
we are prepared to stay the course. “Investingfor the long term is an advantage” is one of
our core investment beliefs. We believe clientsshould benefit from our long-term investment
approach in order to generate sustainable
returns.
On all portfolios where our Minimum Standard
and Exclusion Policy applies, we exclude
investment in assets from issuers that we deemof the lowest ESG quality (rated G on our A-G
scale). However, exclusion is a last resort option.
The Amundi ESG rating scale and MinimumStandards and Exclusion Policy are discussed indetail in further sections in this document.
Our ambition is to apply Amundi’s Stewardship
Policy to all portfolios directly managed by
Amundi, wherever applicable6. Our responsible
investment solutions encompass different
approaches that can be exclusive or combined:
best-in-class screening with ESG-risk budget
or selectivity requirements, negative or
norms-based screening, activity-based or
sector-based screening, sustainability-themed
investing, impact investing, and additional
corporate engagement and shareholder action
approaches.
In all instances, we ensure that our contractual
relationships with clients explicitly set out
our responsible investment approach andstewardship on their behalf, and we work
diligently to try to deliver those client
requirements. Amundi always welcomes the

6. Refer to “Purpose and Scope” on page 2 for out or partially out of scope affiliates and associated entities of the AmundiGroup.

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opportunity to be fully transparent and openwith its clients, and maintains clear channelsof communication. This includes providing
investors with comprehensive disclosureson our responsible investment approach,
responsible investment policies and specificreports. Furthermore, Amundi is able to provide
both general and customised ESG reporting
depending on individual client needs.

Going further: ESG
Ambitions 2025
Following the completion of our first ESG Action
Plan, Amundi has launched in December 2021
a new ESG Ambitions 2025 plan that will allow
us to continue deepening ESG integration in
investment solutions, strengthen our investment
offering for sustainable development and
set internal alignment objectives in line with
Amundi’s ESG commitments. This new 3-year
Action Plan is comprised of an ambitious set ofgoals that aims to address clients’ current andfuture responsible investing needs. Please finddetails of our corporate ambitions in the ESG
Ambitions 2025 brochure here.

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A dedicatedorganisation
01 Specialised
resources____A dedicated business line
Amundi has integrated ESG at the heart ofits management and has created a dedicatedResponsible Investment business line, organizedin five main teams.

A. ESG Research, Engagement
and VotingThis international team spans across Paris,
London, Singapore, Beijing and Tokyo. The ESG
analysts monitor each business sector and maininvestment segments (sovereigns, sustainablebonds, etc.) on key ESG topics. They assesssustainability risks and opportunities as well as
negative exposure to sustainability factors, andselect relevant KPIs7 and weights in Amundi’s
ESG scoring system. ESG analysts work
alongside a team of specialists dedicated toexercising voting and conducting pre-meeting
dialogue. These specialists exercise voting rights
at General Assemblies’ of companies in which
Amundi invests on behalf of its clients. ESG andcorporate governance analysts meet, engage
and aim to maintain constant dialogue withcompanies to improve their ESG practices andimpacts. The members of the team work actively
with fund managers and financial analysts tostrengthen ESG knowhow and expertise acrossthe whole Amundi Group, including a cultureof ambitious and impactful engagements withissuers across investment platforms.

7. Key Performance Indicator.

B. ESG Method and Solutions
This team of quantitative analysts and financial
engineers is in charge of developing andmaintaining (in collaboration with the ESG
Research team and the ESG Global DataManagement team) Amundi’s proprietary ESG
scoring system. Leading the development andintegration of ESG data solutions and scores,
they enable financial analysts and portfolio
managers to integrate ESG and sustainability
considerations into their investment decisions,as well as business development teams tocreate innovative investment solutions by
integrating sustainability-related data within
financial products (ESG ratings, climate data,
impact metrics, controversies…). They oversee
the development and integration of analytical
ESG tools in Amundi Portfolio Management
Systems and Client Reporting Systems and arealso in charge of implementing clients’ specific
ESG exclusion rules.

C. ESG Business Development &Advocacy
Present in Paris, Munich, Tokyo, Milan and Hong
Kong, this team is in charge of supporting anddeveloping the responsible investment offeringand solutions that match investors’ needs andchallenges in collaboration with investment
platforms and marketing units. It provides
responsible investment expertise, advisory andservices to all of Amundi’s clients and business
partners. It contributes to ESG external andinternal advocacy of responsible investment andoversee Amundi’s engagement with responsible
finance initiatives. It develops training programsfor our clients and internal employees.

9Amundi - Global Responsible Investment Policy

D. ESG Regulatory Strategy
Within the Responsible Investment businessline, this team is responsible for ESG regulatory
issues. It supports Amundi’s development by
anticipating the impact of future ESG regulations,and contributes to the financial sectors work on
the continuous strengthening of the responsible
investment framework in all jurisdictions.

E. ESG COO OfficeThis team is in charge of coordinating andstreamlining
developments
betweenthe
Responsible Investment business line andthe support functions of the Group, such as
producing dashboards for the monitoring of
the business line’s activities (business, budget,
IT, audit, projects), and supervising majortransversal projects.

ESG at the core of ourpractices
Responsible Investment businessline level
The Responsible Investment business line isan expertise centre that provides ESG rating,assessment and scoring methodologies as wellas qualitative analysis. A large perimeter of listedcompanies and issuers are evaluated based on
Amundi’s proprietary ESG rating methodology
described in the section ESG Analysis. Thisbusiness line also provides research, supportand knowledge transfer to the investment hubs
across the firm. All team members collaborate
with investment professionals to help them
integrate ESG into their investment processes
and expertise where relevant.

Investment level
ESG analysis is embedded into Amundi’s
portfolio management systems, made available
in real time in the fund managers’ tools to provide

them with a seamless access to corporate
and sovereign issuers’ ESG ratings alongside
financial ratings8.
Portfolio managers and investment analysts
from all investment platforms have access at all
times to issuers’ ESG scores, and related ESG
analytics and metrics.
This enables fund managers to factor insustainability risks and adverse impact onsustainability factors in their investment
decision process and apply Amundi’s MinimumStandards and Exclusion Policy wheneverapplicable9. They are also able to design andmanage their portfolio in compliance withspecific ESG rules and ESG objectives that may
apply to the investment strategies and productsthat fall under their remit.
Across Amundi, a broad range of responsible
investment solutions are managed, including
impact, sustainability-themed and best-in-classstrategies to answer different investment needs
and sustainability preferences.
In addition, Amundi is committed to integrate
ESG criteria into the investment process ofactively managed open-ended funds10, with theobjective to maintain portfolio average ESG
scores above the average ESG score of theirrespective investment universe in addition tofinancial objectives.

Risk Management level
ESG criteria are embedded within Amundi’s
control framework, with responsibilities spread
between the first level of controls performed by
the Investment teams themselves and second
level of controls performed by the Risk teams,
who monitor compliance with ESG objectives
and constraints of investment portfolios at
all times. The Risk department is part of the
responsible investment governance (describedin section “Dedicated governance”). They
oversee adherence to regulatory requirements,
contractual requirements and management ofrisks related to these topics.

8. For investment universes and issuers covered by Amundi ESG rating, see next section.
9. For more detailed information on the scope of application of the Exclusion Policy, please refer to the Appendix at page35.
10. Refer to “Purpose and Scope” on page 2 for out or partially out of scope affiliates and associated entities of theAmundi Group. For in scope entities, see ESG Product Policies section. Please review funds’ offering documents forcomplete information on responsible investment characteristics.

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Risk teams monitor extra-financial characteristics(“ESG rules”) in the same way any investment
rule is monitored within their overall perimeterof control, relying on the same tools andprocedures as other investment professionals
across Amundi Group. The ESG rules consist of
regulatory, exclusion rules internal to Amundi
and/or demanded by a client, as well as eligibility
criteria and portfolio management rules specificto investment portfolio as described in theirlegal documentation. Regarding these rules,
compliance controls are automated in Amundi’s
proprietary compliance tool with:– Pre-trade alarm or blocking alerts, in particularwith regards to exclusion policies;(Sector Policy, Exclusion Policy, Voting Policy,
Engagement Policy);– Monitor key strategic projects.

ESG Rating Committee
Chaired by the Chief Responsible Investment
Officer, this Committee is composed of senior
managers from investment platforms, risk andcompliance divisions, and meets every monthwith the aim to:– Validate Amundi’s standard ESG methodology;– Review exclusion policies and sector-specificpolicies and approve their rules of application;– Post-trade alerts: fund managers are notified
of potential breaches and are required to bring
portfolios back into compliance.

– Review and decide on individual ESG rating
issues, and advise on new ESG cases whenevernecessary.

Across the firm

Voting Committee

Amundi’s responsible investment ambition is
supported across the organization with specificresources dedicated to ESG in other divisions.

This Committee is chaired by the member of
executive management in charge of Responsible
Investment supervision. It meets once a year to
approve the Voting Policy, monthly and on an
ad hoc basis during the rest of the year, with the
purpose to:– Advise on voting decisions at the General
Meetings for special cases; members arecalled upon to give their views in an expert
capacity;

02 Dedicated 				governanceWith the support of these teams, four
Responsible Investment Steering Committees
have been put in place and are monitored by
Amundi’s CEO on a regular basis.

ESG and Climate Strategic
Committee
This Committee, chaired by Amundi’s CEO,meets every month to set the strategicorientations of the Amundi Group with respect
to ESG integration, sustainability and climate,and determine and approve the ESG and climate
policies applicable to investments. Its purpose isto:– Steer, confirm and monitor Amundi's climate
and responsible investment strategy;– Validate the main strategic orientations of
the Global Responsible Investment Policy– Approve Amundi’s Voting
the entities covered11) and
implementation;

Policy (forits rules of– Approve specific/local approaches that are
not directly covered by the Voting Policy;– Approve periodic reports on voting disclosures.

ESG Management Committee
This weekly Committee is chaired by themember of executive management in charge of
Responsible Investment supervision. It focuses
on defining the responsible investment strategy
and monitoring its implementation by the
Responsible Investment business line, including
monitoring of business development, humanresources, budgeting, regulatory projects,
audits, responsible investment communication
campaigns and market initiatives.

11. KBI Global Investors Ltd, Amundi US or Joint ventures voting policies are not under the remit of this committee’s
supervision. The relevant Joint-Ventures are listed on page 2.

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ESG analysis andintegration
Amundi has developed its own ESG analyticalframework and scoring methodology. Thismethodology is both proprietary and centralised,enabling a self-defined, independent andconsistent approach to responsible investing
throughout the organisation.
Amundi has developed two main ESG scoring
methodologies, one for corporates issuing listed
instruments and one for sovereign entities.
Bespoke methodologies and frameworks
developed for specific needs and asset
classes or instruments such as real assets12 or
use-of-proceeds bonds complement thesemethodologies.

Our approach is based on texts that are
universal in scope, such as the United Nations
Global Compact (UNGC), the Organisation for
Economic Co-operation and Development’s(OECD) Principles of Corporate Governanceand the International Labour Organization (ILO)
recommendations.
The ESG score aims to measure the ESG
performance of an issuer, e.g. its ability toanticipate and manage the sustainability risks
and opportunities inherent to its industry and to
its individual circumstances. The ESG score also
assesses the ability of the issuers’ management
team to handle potential negative impact of
their activities on the sustainability factors13.

We source our data from 16 main data providers:
Generalists

ClimateControversies / controversial weapons

Sovereigns

12. Including but not limited to: real estate, private equity, private debt, impact investing, infrastructure and fund of funds
13. Sustainability risk means an environmental, social or governance event or condition that, if it occurs, could causea negative material impact on the value of the investment - adverse impacts on sustainability factors are impacts ofinvestment decisions that result in negative effects on sustainability factors.

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01 ESG analysis forcorporate issuers
Best-in-Class principles
Amundi bases its ESG analysis of corporates on a
best-in-class approach. Each issuer is assigned aquantitative score assessed around the averageof the issuers’s sector, which separates what we
believe are best practices from worst practices.
Amundi’s assessment relies on a combinationof extra financial data from third parties andqualitative analysis of associated sector andsustainability themes. The quantitative scoreis translated into a letter rating, using a sevenpoint scale from A to G, whereby A is for the bestpractices, and G for the worst ones. As part of
the application of Amundi’s Minimum Standards
and Exclusion Policy, G-rated companies are
excluded from the investment universe14.

ESG dimensions
Amundi’s analysis framework has been
designed to assess corporate behaviour inthree dimensions: Environment, Social, andGovernance (ESG). Amundi assesses companies’
exposure to ESG risks and opportunities,
including sustainability risks and impact onsustainability factors, and how corporates
manage these challenges in their respective
sectors. As far as issuers of listed securities areconcerned, Amundi assigns a unique score atissuer level, which is attributed to all instrument
types across the capital structure.

A. Environmental dimension
There are risks and opportunities linked toenvironmental issues. Our analysis on thisdimension examines how issuers address this
topic, and assesses companies’ ability to control
their direct and indirect environmental impact,by limiting their energy consumption, reducing
theirgreenhouseemissions,developing
solutions to fight resource depletion andprotecting biodiversity.

B. Social dimension
In this dimension, we measure how issuers
manage their human capital and stakeholders15,
drawing on fundamental principles with auniversal reach. This dimension covers multiple
themes including the social aspect linked
to issuers’ human capital, those linked tohuman rights, and the responsibilities towards
stakeholders.

C. Governance dimension
In this dimension, we assess issuers’ ability toestablish an effective corporate governanceframework that ultimately supports the issuers’
value over the long-term.

14. Refer to “Purpose and Scope” on page 2 for out or partially out of scope affiliates and associated entities of theAmundi Group. For more detailed information on the scope of application of the Exclusion Policy, please refer to the
Appendix at page 35.
15. Stakeholders other than shareholders.

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ESG specific criteria
Our ESG analysis framework is comprised of 38 criteria, of which 17 are cross-sector criteria and 21
sector-specific criteria. These criteria are designed to assess how sustainability issues might affectthe issuer as well as the quality of the management of these issues. Impact on sustainability factors
as well as quality of the mitigation actions are also considered. These criteria are available in fundmanagers’ front office portfolio management system.

CROSS-SECTOR
CRITERIA

Environment

SocialGovernance• Emissions & Energy• Water Management• Biodiversity & Pollution• Supply Chain - Environment• Health & Safety• Working Conditions• Labour Relations• Supply Chain - Social• Product & Customer
Responsibility• Community Involvement& Human Rights• Board Structure• Audit & Control• Remuneration• Shareholders’ Rights• Ethics• Tax Practices• ESG Strategy

Environment
SECTOR-SPECIFIC
CRITERIA• Clean Energy• Green Car• Green Chemistry• Sustainable Construction• Responsible Forest Management• Paper Recycling• Green Investing & Financing• Green Insuring• Green Business• Packaging

To be effective, ESG analysis must be focusedon the most material criteria depending on thebusiness and sector activity. The weighting of
ESG criteria is therefore a critical element of our
ESG analytical framework. For each sector, ESG
analysts weigh the criteria deemed the mostimportant.
Our ESG analysts will typically increase theirlevel of scrutiny and expectations whenever
the risk faced by a company on any given ESG
criteria is deemed high and material.
For example, in the Household & Personal
products sector, the players in the industry
need to make their production and packaging
more environmentally friendly, partially driven
by regulation. Our ESG analyst will therefore
consider the Packaging and the Biodiversity& Pollution but also the Product & Customer
Responsibility. We believe these criteria are all
the more relevant in that they represent a risk
for a manufacturer.

Social
• Bioethics• Responsible Marketing• Healthy Product• Tobacco Risk
• Vehicle Safety• Passenger Safety• Responsible Media• Data Security & Privacy• Digital Divide• Access to Medicine• Financial Inclusion

Example of sector weight attributions

E

S

G

Household & Personal
products

36%

34%

30%

Automotive

40%

34%

26%

Banking

24%

29%

47%

Telecom

15%

53%

32%

Breakdown of the environmental criteria’s
weight in the Household & Personal
Products sector
9,7%

Biodiversity & Pollution

10,5 %

5,5 %Packaging

Emissions& Energy

5%

Supply Chain –Environment

5,5 %

Water
Management

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ESG scoring and rating
methodology

02 ESG analysis forsovereign issuers

ESG ratings are calculated by using the ESG
criteria and weights assigned by the analysts
and combining the ESG scores obtained fromour external data providers. At each stage of thecalculation process, the scores are normalized
into Z-scores. Z-scores are a way to compare
results to a “normal” population (deviation of
the issuer's score compared to the averagescore of the sector, by number of standard
deviations). Each issuer is assigned with a scorescaled around the average of their sector, which
separates what we believe are best practices
from worst practices at sector-level. At theend of the process, each company is assigned
an ESG score (approximately between -3 and+3) and the equivalent on a scale from A to G,
whereby A is the best, and G the worst. Rating
D represents the average scores (from -0,5 to+0,5); each letter matching a standard deviation.

Amundi’s ESG sovereign scoring methodology
aims at assessing the ESG performance ofsovereign issuers. E, S and G factors can have an
impact on the issuer’s ability to repay its debt in
the medium and long-term. They can also reflect
on how countries are faring in dealing with major
sustainability issues that affect global stability.
Amundi’s methodology relies on a set of about
50 ESG indicators deemed relevant by Amundi
ESG Research to address sustainability risks andsustainability factors16. Each indicator can weighin several data points, coming from different
sources, including open-source international
databases (such as from the World Bank
Group, the United Nations, etc.) and proprietarydatabases. Amundi has defined the weightsof each ESG indicator contributing to the final
Amundi sovereign ESG scores, and its various E,
S and G sub-components.

There is only one ESG rating assigned to eachissuer, regardless of the chosen reference
universe. The ESG rating is thus “sector neutral”,
that is to say that no sector is privileged or, on
the opposite, disadvantaged.

The indicators are sourced from an independent
data provider.

ESG ratings are updated on a monthly basis,
based on the raw data provided by our external
data providers’ raw data. Developments on
issuers’ ESG practices are followed continuously.
Our ESG analysts review ESG analysis & rating
methodology as required by changes in thebusiness and policy environment, emerging
material ESG risks, or the occurrence ofsignificant events.

All indicators have been grouped into 8
categories in order to provide greater clarity,each category falling into one of the E, S or G
pillars. Similarly to our corporate ESG rating
scale, issuers’ ESG score is translated in an ESG
rating ranging from A to G.

Environment

Climate Change - Natural
CapitalSocialHuman Rights - Social
Cohesion - Human Capital Civil Rights

Governance

Government Effectiveness Economic Environment

16. Sustainability risk means an environmental, social or governance event or condition that, if it occurs, could causea negative material impact on the value of the investment. Adverse impacts on sustainability factors are impacts ofinvestment decisions that result in negative effects on sustainability factors.

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03 Other types of
instruments or 		
issuers

By integrating such issues, investors could bettertake into account long-term risks (financial,
operational, reputational, etc.), fulfilling boththeir fiduciary duty and potential commitment
to act as responsible investors.

Amundi’s main ESG rating methodology does
not cover some instruments and issuers ofAmundi’s investable universes, either due tothe nature of the instruments or due to a lackof coverage by existing external data providers(this situation applies for instance to real assets,
US municipal bonds or securitized products).
To expand its coverage, Amundi has developed
specific methodologies that apply to real assets(private equity, private debt issuers, impact
investing, real estate17, infrastructure, fund offunds), agencies and local authorities, and to
specific instruments such as green or social
bonds. Even if each methodology is specific,
they share the same target, which is the ability
to anticipate and manage sustainability risks
and opportunities as well as the ability tohandle their potential negative impacts on thesustainability factors.

We embrace the concept of “double materiality”
around which we build our proprietary ESG
analysis and rating methodology, as we
believe both sets of criteria are material when
making investment decisions in the interestsof our beneficiaries, with the aim to generate
sustainable returns. This means that our ESG
analysis aims at not only assessing the way
ESG factors can materially impact the value ofcompanies, but also how companies can impact
the environment, and social matters or humanrights.

04 Integrating ESG 		
into our analysis
and investment
processes
Wefirmlybelievethat
ESG
analysisconsolidates value creation as it provides aholistic understanding of the overall company.
This view has led us to integrate ESG criteria
across our active management processes,
and to implement an Engagement Policy,
where applicable. Underlying ESG integrationis the conviction that a strong sustainable
development perspective enables issuers tomanage their regulatory and reputational risks
better and improve their operational efficiency.

We therefore constantly monitor our investee
companies, across all E, S and G factors as well
as more traditional financial metrics. We seek
to identify problems and concerns early before
they damage company performance and affectour clients’ investment performance.
Our proprietary ESG rating derives fromthe aggregation of E, S, and G ratings andanalysis from a range of sources, and it is now
available for more than 18,700 issuers18. Amundi
investment portfolios may invest in a variety of
instruments, issuers or projects, with different
ESG objectives and constraints. However, ESG
ratings and the associated criteria producedby Amundi ESG Research, and additionalsustainability-related indicators, are madeavailable to all our fund managers’ on theirportfolio management system. This enables
them to integrate sustainability issues into theirinvestment decisions and apply any constraints
relevant for their portfolios.

17. For more information: https://www.amundi.com/institutional/real-estate, https://amundi.oneheart.fr
18. Data as of September 2023.

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Amundi - Global Responsible Investment Policy

05 Responsible 			external managers
selection

06 Responsible
external fundselection

In cases where Amundi sub-contracts the
management of assets to investment managers
outside the Amundi Group, two due diligences
are performed as part of our routine investment
due diligence: an operational due diligence(ODD) performed at company level, and an
investment due diligence (IDD) performed at thetargeted investment process level (following a
positive result of the ODD). The ESG credentials
are assessed as part of the latter one through a
two-pronged approach.

In cases where Amundi selects responsible
funds outside the Amundi group, both ODD
and IDD are performed. The ESG credentials areassessed as part of the latter through a twopronged approach.

We perform a qualitative assessment based on
the Responsible Investment Policy of the asset
manager, including its exclusion policy and its
responsible investment approaches (best-inclass, ESG integration, impact, voting policy,
engagement policy). It is complemented by
specific questions on the targeted investment
process.

		

We perform a qualitative assessment basedon the Responsible Investment Policy of theasset manager, including its exclusion policy,
its responsible investment approaches (bestin-class, ESG integration, impact, voting policy,
engagement policy) and also at financial
product level (labels, SFDR and EU Taxonomy
characteristics, Principal Adverse Impacts, GHG
emissions and reporting).
We also perform a quantitative ESG scoring
based on the holdings of the portfolio, using
our proprietary ESG methodology and scores,
to assess the consistency with the qualitative
assessment.

We also perform a quantitative ESG scoring
based on the holdings of the portfolio, using
our proprietary ESG methodology and scores,
to assess the consistency with the qualitative
assessment.
When we delegate the management of assets toexternal fund managers, we also send them a listof issuers to be excluded on a monthly basis tocomply with Amundi Standards and Exclusions.
When Amundi solely performs a fund hosting
function, then the exclusion list does not apply19.

19. Refer to “Purpose and Scope” on page 2 for out or partially out of scope affiliates and associated entities of theAmundi Group. For more detailed information on the scope of application of the Exclusion Policy, please refer to the
Appendix at page 35

17Amundi - Global Responsible Investment Policy

07 Disclosure on theuse of raw ESG
data, third-party
ESG scores and
ESG data products
Amundi uses ESG scores and other ESG
indicators using inputs from third-party data
vendors to set sustainable characteristics orobjectives for a certain number of investment
portfolios managed by Amundi Groupmanagement companies.
While Amundi exercises reasonable careand diligence when selecting ESG data andservice providers and the specific scores anddata products they provide, ESG scores andindicators used by Amundi may be subject tothe following limitations that might undermine
the attainment of the sustainable characteristics
of objectives of the investment portfolios.
– Heterogeneous methodologies and lack of
independent verification or auditing process
for reported “raw data”: raw data inputs
reported by corporates or other economic
agents (as well as raw inputs collected bydata vendors) are generally not supervisedor regulated, and not verified by a third party.
As such, raw data quality may vary dependingon the quality of the sustainability disclosure
framework of the reporting entity. Amundi
engages with reporting entities to enhancetheir sustainability disclosure to ensure theymeet best standards, as well as with publicbodies to develop ambitious disclosure
frameworks.

– Reliability issues of ESG scores and data
products: ESG scores and indicators may
suffer from insufficient quality in reported data,
issues in data collection and dissemination not
captured by data quality controls, and issues
in model computations for estimated data.
Amundi ESG Method and Solutions team andAmundi Global Data Management team are
responsible for the oversight and engagementof Amundi ESG data vendors and to seek
appropriate remediation whenever data
quality issues are identified.
– Lack of data availability and coverage:
unavailable raw data are in some instances
replaced by estimated data by third-party
data vendors. Moreover, some investment
portfolio with sustainable characteristics may
invest into assets with incomplete ESG data
coverage. Amundi generally set minimum
coverage ratio among the set of minimum
criteria that need to be met to enable any
sustainable characteristics’ claim (please
always refer to the investment portfolios
offering documents and periodic reports forcomplete information on ESG integration).

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Amundi - Global Responsible Investment Policy

Minimum Standards
and Exclusion
PolicyAs part of its fiduciary responsibility, Amundi has
set minimum standards and exclusion policies
on critical sustainability topics, triggering
specific monitoring, and escalation procedures
when breaches are identified, that can lead toengagement, specific voting actions (whenapplicable) or exclusion.
Amundi’s Minimum Standards and Exclusion
Policy is implemented in our actively managed
portfolios and ESG passive products, unlessotherwise requested by our clients and always
subject to applicable laws and regulations
prohibiting their implementation.
The ESG and Climate Strategic Committee sets
out the guidelines of the Minimum Standards andExclusion Policy and the ESG Rating Committee
validates the rules for implementation. Excluded
issuers20 are flagged in fund managers’ portfolio
management system and pre-trade blocking
controls are implemented in the compliance tool
to prevent any purchase, except where noted.
Second level of controls are performed by the
Risk teams.
For any new mandate or dedicated fund,
Amundi’s Minimum Standards and Exclusion
Policy shall be implemented in accordancewith our pre-contractual documentation, unlessotherwise requested by the client.

– For ESG passive products: All22 ESG ETFs
and index funds apply Amundi’s MinimumStandards and Exclusion Policy.
– For non-ESG passive products: The fiduciary
duty in passive management is to replicate
in index as closely as possible. The portfolio
manager has thus limited leeway and has
to meet the contractual objectives to getpassive exposure fully in line with requested
benchmarks. Amundi index funds/ETFs
replicating standard (non-ESG) benchmarks
do not apply systematic exclusions beyond theregulatory ones. However, for securities thatare excluded due to the Miminum Standards
and Exclusion Policy23 applicable to Amundi’s
active investment universe, but that could bepresent in non-ESG passive funds, Amundi
has strengthened its engagement and voting
actions that may lead to a vote against thedischarge of the board or management, or
the re-election of the Chairman and of some
Directors.
The Minimum Standards and Exclusion
Policy distinguishes between corporates andsovereigns exclusion criteria. The corporate
criteria target company activities and practices
that can lead to the exclusion of securities ofa company. Sovereign criteria can lead to the
exclusion of sovereign bonds.

For passive portfolios, the application of the
Minimum Standards and Exclusion Policy differs
between ESG products and non-ESG products21:

20. Please refer to Exclusion Policy Scope of Application in the Appendix at page 35.
21. See Appendix at page 35 for an exhaustive view of the scope of application of Amundi’s Exclusion Policy.
22. Unless otherwise requested by the client in case of dedicated portfolios
23. See Sector Policies section.

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Amundi - Global Responsible Investment Policy

01 Normative
exclusions linked
to international
conventions
Amundi excludes the following issuers:– Issuers involved in the production, sale,storage or services for and of anti-personnel
mines and cluster bombs, prohibited by the
Ottawa and Oslo treaties24;– Issuers involved in the production, saleor storage of chemical25, biological26 anddepleted uranium27 weapons;– Issuers that violate, repeatedly and seriously,
one or more of the ten principles of the UN
Global Compact28, without credible corrective
action.

02 Sector policies

Phasing out coal is paramount to achieve thedecarbonisation of our economies. That is thereason why Amundi is committed to phase out
thermal coal from its investments by 2030 inOECD and EU countries and by 2040 in nonOECD countries. Consistent with the United
Nations Sustainable Development Goals (SDGs)
and the 2015 Paris Agreement, this strategy isbased on the research and recommendations of
the Crédit Agricole Scientific Committee, whichtakes into account scenarios designed by theInternational Energy Agency’s (IEA) Sustainable
Development Scenario, Climate Analytics
Report and Science Based Targets.

“Achieving a state of net-zeroemissions at the planetarylevel requires real world cuts ingreenhouse gas (GHG) emissions
from companies’ value chains, andnot simply a reduction in exposure
to emissions within portfolios”30
Science Based Targets initiative (SBTi)

A - Thermal Coal
Objective and scope
Coal combustion is the single largest contributor
to human-induced climate change29. In 2016,
Amundi implemented a dedicated Sector Policyon thermal coal, triggering the exclusion ofcertain companies and issuers. Each year sincethen, Amundi has progressively reinforced therules and thresholds of its thermal coal Sector
Policy (see below “Exclusions as a tool to deal
with unsustainable exposures”).

In line with our 2030/2040 phase out timelinefrom thermal coal, the following rules andthresholds are the baseline for which companies
are considered too exposed to be able to phaseout from thermal coal at the right pace.
The policy is applicable to all investee companies,
but predominately affects mining, utilities, andtransport infrastructure companies. This policy isapplicable across all actively managed strategies
and passively managed ESG strategies overwhich Amundi has full discretion31.

24. Conventions Ottawa 3/12/1997 and Oslo 3/12/2008, ratified by 164 and 103 countries respectively as of July 2018
(including European Union countries and excluding the United-States).
25. Convention on the Prohibition of the Development, Production, Stockpiling and Use of Chemical Weapons and on their
Destruction 13/01/1993.
26. Convention on the Prohibition of the Development, Production and Stockpiling of Bacteriological (Biological) andToxin Weapons and on their Destruction 26/03/1972
27. Although not subject to a ban or restriction by international treaty, depleted uranium is often considered ascontroversial weapon.
28. United Nations Global Compact (UN Global Compact): “A call to companies to align strategies and operations with
universal principles on human rights, labour, environment and anti-corruption, and take actions that advance societal
goals.”
29. IPCC, 2022: Summary for Policymakers. In: Climate Change 2022: Mitigation of Climate Change. Contribution of Working
Group III to the Sixth Assessment Report of the Intergovernmental Panel on Climate Change [P.R. Shukla, J. Skea, R. Slade, A.
Al Khourdajie, R. van Diemen, D. McCollum, M. Pathak, S. Some, P. Vyas, R. Fradera, M. Belkacemi, A. Hasija, G. Lisboa, S. Luz,
J. Malley, (eds.)]. Cambridge University Press, Cambridge, UK and New York, NY, USA. doi: 10.1017/9781009157926.001.
30. SBTi-Finance-Net-Zero-Foundations-paper.pdf
31. Refer to “Purpose and Scope” on page 2 for out or partially out of scope affiliates and associated entities of the Amundi Group.
For more detailed information on the scope of application of the Exclusion Policy, please refer to the Appendix at page 35.

20 Amundi - Global Responsible Investment Policy

Using our role as investors to
influence issuers to phase out
thermal coalAmundi engages with all companies that havethermal coal exposure (based on revenue) inwhich Amundi portfolios are invested, and thathave not yet published a thermal coal phaseout policy consistent with Amundi’s 2030/2040
phase out timeline.
In addition, for companies that are either
excluded from Amundi’s active investment
universe according to our policy (see below),or have thermal coal policies that Amundi
considers lagging, Amundi escalation measuresconsist in voting against the discharge of theboard or management or the re-election of the
Chairman and of some Directors.

Exclusions as a tool to deal withunsustainable exposures
Where applicable32, Amundi excludes:– Mining, utilities, and transport infrastructurecompanies that are developing thermal coalprojects with a permitted status and that arein the construction phase.
Companies with thermal coal projects in earlier
stages of development, including announced,
proposed, with pre-permitted status, aremonitored on a yearly basis.
Concerning mining extraction, Amundi excludes:– Companies generating more than 20% ofrevenues from thermal coal mining extraction;– Companies with annual thermal coal extractionof 70 MT or more without intention to reduce.
For companies considered too exposed to beable to phase out from thermal coal at the rightpace, Amundi excludes:– All companies that derive over 50% of revenues
from the thermal coal mining extraction andthe thermal coal power generation;– All companies that derive between 20% and
50% of revenues from the thermal coal power
generation and the thermal coal mining
extraction, with a poor transition path33.

Implementation
To assess companies’ thermal coal exposure,Amundi utilizes fossil fuel exposure metrics fromdata providers (Trucost and MSCI). This allows
us to have a large data coverage from a rangeof sources integrated into our ESG analysis
and rating methodology. This also allows us togain a more comprehensive understanding ofcompanies’ thermal coal exposure and provide
our investment teams with additional insights
on the topic. When both providers have thermal
coal-related data for the same issuer, we apply
a conservative approach, which consists inretaining the data with the highest thermal
coal exposure between the two providers. Due
diligence can also be performed to enrich or
challenge the information received by providers.
To assess the development of new thermal
coal capacities, Amundi uses different sources
including the official exclusion list from Crédit
Agricole Group based on information from
Trucost. Due diligence can also be performed toenrich or challenge the information received by
the provider and sources.

B – Unconventional Fossil
Fuel
Objective and scope
Investing in companies significantly exposed
to unabated fossil-related increasingly entailsocial, environmental and economic risks. Once
produced, shale oil, shale gas or oil sands do notdiffer from natural gas or oil that are expected
to continue contributing to the global energy
mix in the forthcoming years under both IEA“Sustainable Development Scenario” and IEA“NZE 2050 Scenario”.

32. Refer to “Purpose and Scope” on page 2 for out or partially out of scope affiliates and associated entities of theAmundi Group. For more detailed information on the scope of application of the Exclusion Policy, please refer to the
Appendix at page 35.
33. Amundi performs an analysis to assess the quality of their phase out plan.

21

Amundi - Global Responsible Investment Policy

However, unconventional oil & gas explorationand production is exposed to acute climate(due to potentially higher methane emissions –if not properly managed – for shale oil and shale
gas and higher carbon intensity for oil sands),
environmental (water use and contamination,induced seismicity and air pollution) andpotential social (public health34) risks.
This policy is applicable across all actively
managed strategies and passively managed ESG
strategies over which Amundi has full discretion.

Exclusions as a tool to deal withunsustainable exposures
Where applicable35, Amundi excludes companies
whose activity is exposed to exploration andproduction of unconventional oil & gas (covering
shale oil, shale gas and oil sands) by over 30%
of revenues.

Implementation
To assess companies’ unconventional fossil
fuel exposure, Amundi utilizes fossil fuelexposure metrics from data providers (MSCI
and Sustainalytics). This allows us to have alarge data coverage from a range of sources
integrated into our ESG analysis and rating
methodology. This also allows us to gain a morecomprehensive understanding of companies’
unconventional fossil fuel exposure and provide
our investment teams with additional insights
on the topic.
Due diligence can also be performed to enrich or
challenge the information received by providers.

C - Tobacco
Objective and scoperights abuses and specific health challenge for
its workforce, has an impact on poverty, hassignificant environmental consequences, andbears substantial economic costs (believed
to be more than USD 1 trillion a year globally,
according to World Health Organisation
estimates36).
In May 2020, Amundi became a signatory of the
Tobacco-Free Finance Pledge.
Amundi caps the ESG rating of issuers exposedto the tobacco value chain and has set an
Exclusion Policy for companies producing
cigarettes. This policy is applicable to thetobacco sector in its entirety, including suppliers,
cigarette manufacturers and retailers.
This policy is applicable across all actively
managed strategies and passively managed ESG
strategies over which Amundi has full discretion.

ESG rating of companies
exposed to tobacco
The ESG rating (ranging from A to G) of thetobacco sector is capped to E. This policy
applies to companies involved in the production,
supply and retailing of tobacco (thresholds forapplication: revenues above 10%).

Exclusions as a tool to deal withunsustainable exposures
Amundi excludes:– Companies that manufacture complete
tobacco products (thresholds for application:
revenues above 5%), including cigarettemanufacturers, as no product could be
deemed to be child labour free.
This policy is applicable across all actively
managed strategies and passively managed ESG
strategies over which Amundi has full discretion.

Tobacco not only has a negative impact on
public health, its value chain faces human

34. https://e360.yale.edu/features/fracking-gas-chemicals-health-pennsylvania
35. Refer to “Purpose and Scope” on page 2 for out or partially out of scope affiliates and associated entities of theAmundi Group. For more detailed information on the scope of application of the Exclusion Policy, please refer to the
Appendix at page 35.
36. https://www.hrw.org/report/2014/05/14/tobaccos-hidden-children/hazardous-child-labor-united-states-tobaccofarming

22

Amundi - Global Responsible Investment Policy

Using our role as investors to
influence issuers
Concerning the remaining exposure tocompanies falling within the scope of our
Exclusion Policy (see above), our policy consistsof voting against the discharge of the board ormanagement, or the re-election of the Chairman
and certain Directors.

Implementation
To assess companies, Amundi uses MSCI as adata provider.

D - Nuclear Weapon
Objective and scope
As stated by the Treaty on the Non-Proliferationof Nuclear Weapons (NPT), “the proliferation of
nuclear weapons would seriously enhance thedanger of nuclear war” and such a war could
create “devastation that would be visited upon
all mankind”. Consequently, there is a “need tomake every effort to avert the danger of sucha war and to take measures to safeguard the
security of peoples”: the fundamental purposeof nuclear weapons should clearly be fordeterrence and trade with extreme care.

of Nuclear Weapons and of States signatoriesof the Treaty on Non-Proliferation of Nuclear
Weapons but not members of NATO;– They are involved in the production of nuclear
warheads and/or whole nuclear missiles; aswell as components that were developed and/or significantly modified for exclusive use innuclear weapons;– They derive over 5% of total revenues fromthe production or sale of nuclear weapons,
excluding revenues from ownership and dual
use components as well as delivery platforms.

Implementation
To assess companies’ exposure, Amundi uses
MSCI and ISS ESG as data providers. ESG
analysts conduct a complementary analysis.
The ESG Rating Committee is informed andvalidates additions to Amundi’s exclusion list.

E - Sovereign Bonds
Countries on the European Union (EU)sanction list with a sanction consisting of asset
freezing, and a sanction index at the highest
level (considering both United States and EU
sanctions) are excluded, after formal review andvalidation from Amundi ESG Rating Committee.

This policy is applicable across all actively
managed strategies and passively managed ESG
strategies over which Amundi has full discretion.

03 Human Rights
PolicyExclusions as a tool to deal withunsustainable exposures

Protecting human rights helps to address societal
inequalities and supports a stable and robust
society. We recognise that companies and regions
may be at different levels of maturity in embedding
human rights into their businesses. At a minimum,and in line with the UN Global Compact, werecognize the need to respect the human rights
principles set up by the International Bill of Rights37
and the International Labour Organization’s
Declaration on Fundamental Principles and Rights
at Work. As a responsible asset manager, we assess
how investees take into account human rights andaddress human rights abuses in their operations.

Amundi restricts investments in nuclear
weapons companies involved in the productionof core components of the nuclear weapon or
dedicated components. Issuers are considered
for exclusions when they fall under at least oneof the three following criteria:– They are involved in the production, sale,storage of nuclear weapons of States nonParty to the Treaty on the Non-Proliferation

37. The International Bill of Human Rights consists of the five core human rights treaties of the United Nations thatfunction to advance the fundamental freedoms and to protect the basic human rights of all people.

23

Amundi - Global Responsible Investment Policy

Objective and scope
Amundi considers it necessary for companies
from all sectors to develop a strategy to ensure
respect for human rights principles both in theirdirect and indirect operations.
Amundi’s human rights policy focuses on
dialoguing with corporates on the protection
and promotion of respect for human rights (indirect operations and throughout the value
chain), by ensuring that companies are taking
the necessary steps to identify salient humanrights risks within their global operations,prevent abuses before they occur, and provide
or advocate for effective remediation whenissues are identified. For companies identified
as particularly exposed to potential risks thatlack sufficient processes or disclosure, andfor companies facing human rights-related
controversies, monitoring is performed. Allcompanies from this focus list are engaged
to trigger improvements. When engagement
fails, we may enact a mode of escalation to
encourage appropriate remediation. Whenan issuer demonstrates severe and repeatedviolations without appropriate remediation,
escalation could lead to exclusion (breach of the
UN Global Compact).
This policy is applicable across all actively
managed strategies and passively managed
ESG strategies over which Amundi has full
discretion. Engagement and voting are applied
across all strategies.

ESG rating of companies
exposed to human rights risks
To assess and monitor issuer conduct withrespect to human rights, we rely on internal
research tools. Our proprietary ESG rating toolassesses issuers using available human rights
data from our data providers. ESG analysts
are also monitoring controversies to identify
corporate human rights violations, using a wide
variety of sources. For issuers that have faced
controversies with poor remediation plans or forwhich engagement has not borne fruit, Amundi
applies overrides of the relevant criteria of the
ESG score and could use escalation throughvoting and up to exclusion if the issuer is deemed
to be in breach of the UN Global Compact.

Using our role as investors to
influence issuers
Human rights engagement follows a twopronged approach. First, we aim to engage
proactively with companies on identificationand management of human rights risks.
Second, we can engage reactively when an
abuse or allegation occurs. Amundi aims toaddress human rights risks by encouraging
companies to acknowledge their exposure tosuch risks and take concrete actions to prevent
and address issues should they occur. We
conduct engagement to encourage companies
to strengthen their human rights policies andprocesses. Our aim is to ensure that company
practices on human rights go beyond a reportingand compliance exercise to have a positive andtangible impact. Through our engagement
activities, we seek to facilitate the market’s
ability to identify and adopt best practices.
When an abuse occurs (or when credible
allegations arise), we work to ensure thatcompanies carry out effective remediation
to those impacted and enhance processes toprevent repeat occurrences. As an investor, we
see engagement as a particular opportunity
to ensure companies learn and improve. If
engagement is unsuccessful, we identify a modeof escalation to enable appropriate remediation.

Implementation
To assess how investees take into accounthuman rights and address human rights abusesin their operations, Amundi utilizes different
sources including its traditional data providers.
Integration into the ESG score, engagement,
potential escalation through voting or exclusion(breach of UN Global Compact) follows theprocesses described in this document.

24 Amundi - Global Responsible Investment Policy

04 Biodiversity &Ecosystem 		Services Policy
Biodiversity and ecosystem services form thefoundation of our societies and global economy.
The science is clear that this biodiversity is at
risk and urgent action is required to halt andreverse its loss. Protecting biodiversity also
helps to address other environmental challenges
such as climate change and social challenges
too. People livelihoods, income, social needs
and health38 may rely on natural resources, andbiodiversity loss may hence have significant
impacts on these. More broadly, biodiversity
and ecosystem services play an essential role inachieving the Sustainable Development Goals.
As a responsible asset manager, we acknowledge
the impact of the biodiversity, and subsequently
its protection and restoration on the value of
our investments. In 2021, Amundi signed the
Finance for Biodiversity Pledge.

Objective and scope
Amundi’s biodiversity policy aims at gathering
what Amundi has been doing on biodiversityrelated topics and connect them to an
overarching policy. This policy focuses on thefour main drivers of biodiversity loss: land andsea use changes, climate change, pollution,
natural resource use and exploitation.39
The policy focuses on companies particularly
exposed to biodiversity harming activities
that are either lacking sufficient processes
or disclosure. It is applicable to issuers withactivities of potential critical impact on forestand deforestation, with activities of potential
critical impact on water, with deep sea mining
and broader extractives activities (metals &mining and oil & gas companies) operating in
biodiversity sensitive areas, activities exposedto pesticide production, as well as major single
use plastic producers and users. All companies
identified are engaged with to trigger
improvements
The caps detailed below are applicable across all
actively relevant managed strategies. Potential
exclusions apply to actively managed strategies
and passively managed ESG strategies overwhich Amundi has full discretion. Engagement
and voting are applied across all strategies.

ESG rating of companies
exposed to biodiversity risks
To assess and monitor issuer conduct withrespect to biodiversity, Amundi relies on internal
research tools. The proprietary ESG rating toolassesses issuers using available environmental
information
from
data
providers.
ESG
analysts also monitor controversies, by usinga wide variety of sources, to identify severe
environmental damages negatively affecting
biodiversity.
Companies may have particular impacts on
biodiversity, either through the nature of theiractivities (such as related to deforestation andecosystem conversion risks commodities for
instance); or based on the location of theiroperations (or supply chain) in biodiversity
sensitive areas.
For issuers with activities of high impact
on biodiversity that present insufficient risk
management, Amundi applies caps (E or F)
to the relevant criteria of the ESG rating. Lackof appropriate process or disclosure represent
other reasons to cap biodiversity-related criteriaof the ESG rating.

38. An estimated 427,000 lives lost each year from pollinators decline, Environmental Health Perspectives, 2022.
39. Climate change is already addressed through Amundi’s Thermal Coal and Unconventional Fossil Fuel existing policies.
Invasive species, considered as the fifth main driver of biodiversity loss by the intergovernmental science-policy platform
for biodiversity and ecosystem services (IPBES), are not explicitly addressed yet by the policy due to a lack of appropriate
data available.

25 Amundi - Global Responsible Investment Policy

Using our role as investors to
influence issuers
Amundi engages with all companies from thefocus list as well as issuers for which biodiversity
is deemed relevant. We engage with companies,
on direct operations and throughout the value
chain, to ask them to better integrate biodiversity
and ecosystem services into their strategy. This
engagement follows a two-pronged approach.
First, we aim to engage proactively withcompanies on identification and managementof biodiversity and ecosystems risks. Second,
we can engage reactively when an abuse or
allegation occurs. In this case, we would seek
to ensure that companies are taking appropriate
measures for effective remediation.
Amundi aims to address biodiversity andecosystem services risks by encouraging
companies to acknowledge their exposure tosuch risks and take concrete actions to prevent
and address issues should they occur. In addition,
depending on the situation, we engage directly
or in collaboration together with other investors.

When engagement fails or if the action /remediation plan of the issuers appears weak, we
may enact a mode of escalation up to exclusionfrom active investment universe, meaning all
active investing strategies over which Amundi
has full discretion. Escalation mode include (inno particular order), negative overrides in one
or several criteria, questions at AGMs, votes
against management, public statements, ESG
rating caps and ultimately exclusion if the matteris critical (see Engagement Policy).

Implementation
To assess the impacts of issuers on biodiversity
loss, Amundi uses different sources of
information including its traditional data
providers. Integration into the ESG scores,
engagement, potential escalation throughvoting or exclusion follow the processes
described in this document.

26 Amundi - Global Responsible Investment Policy

Engagement Policy
At Amundi, engagement is a continuous andpurpose driven process aiming at influencing
the activities or behaviour of companies
therefore, it must be result driven, proactive,
considering double materiality, and integrated
in our global ESG process. Engagement
differs from corporate access and traditional
dialogue with a corporate. It aims at influencing
the activities or behaviour of companies toimprove ESG practices or their impact on key
sustainability linked topics. More specifically,
engaging implies having a specific agenda andtargets that focus on real-life outcomes within a
specific timeframe.
Engagement activity is led by the ESG Research,
Engagement and Voting team. It involves ESG
analysts and corporate governance analysts.
Engagement can also be achieved either byfinancial analysts or portfolio managers. In any
case, the ESG Research, Engagement and Voting
team ensures the consistency, traceability andquality of these engagements.
Our pro-active Engagement Policy seeks to:– Contribute to best practice dissemination anddrive a better integration of sustainability in
our investees’ governance, operations andbusiness models;– Trigger positive change concerning how
investees manage their impacts on specifictopics paramount to the sustainability of oursociety and our economy;– Support the investees in their own transition
towards a more sustainable, inclusive and low
carbon business model;– Push investees to increase their level ofinvestment in Capex/R&D in highly needed
areas for this transition.
In addition, our Voting Policy makes best useof our duties as part owners of companies andemphasize the need:– For an accountable, diversified & wellfunctioning board,– For corporates’ governance and board tocome to grasp with environmental and social
challenges,– To ensure that boards & corporates areappropriately positioned and prepared tohandle the transition towards a sustainable,
inclusive and low carbon economy.

Amundi engages withissuers around six mainareas
– Transition towards a low carbon economy,– Natural capital preservation (ecosystem
protection & fight against biodiversity loss),– Social cohesion through the protection of
direct & indirect employees, promotion ofhuman rights,– Client, product & societal responsibilities,– Strong governance practices that strengthen
sustainable development,– Dialogue to foster a stronger voting exercise &a sounder corporate governance.
Amundi engages with investees or potential
investees at the issuer level regardless of thetype of holdings held. Issuers engaged with areprimarily chosen based on the level of exposure
to the engagement subject (often known as
the engagement trigger). Amundi also engages
at the “security level” (for example Green,
Social, Sustainable bonds, funds, asset-backed
securities (ABSs), etc.) to promote better
practices and transparency.
Amundi engagement spans across different
continents and takes into account local realities.
The aim is to have the same level of ambition
globally but adapt questions and intermediate
milestones across the different geographies.
We also wish our engagement activities to be
impactful and additive to the global effort of thefinancial community.
Companies’
engagement
timelinevariesdepending on the agenda, but the average
engagement period is approximately 3 years.
Amundi defines different milestones and27

Amundi - Global Responsible Investment Policy

engagement developments that are sharedinternally via our research platform, available toall investment platforms. Formal assessments
are carried out, at least on a yearly basis.
Amundiconducts
engagements
bothindividually and collectively with other investors.
Collective efforts can often have a great impact.
Collaborative initiatives can provide additional
scale and scope for engagement or provide
opportunities for greater impact.
We wish to have a collaborative, supportive,
and pragmatic yet ambitious dialogue with ourinvestees, to inspire a wide range of actions
that will benefit not only the issuers but also
all its stakeholders with the view to generate
sustainable return over the long-run. We
truly believe that dialogue is the cornerstoneof a sound, strong development towards asustainable and inclusive low carbon economy
and sustainable returns.

01 Measuringand monitoring
engagement
progress
To track issuer specific engagement objectives,and subsequent improvement, Amundi has
created a proprietary engagement reporting
tool. This tool records the feedback given toissuers on specific engagement topics (interms of KPIs for performance improvements)
and tracks issuer performance towards theseobjectives. All open engagements are therefore
recorded in a central tool shared with all
investment professionals, for transparency
and traceability reasons. Any fund manager or
financial analyst can contribute.
Amundi assesses the progress made by theissuer towards certain engagement objectives
through the use of milestones. Our firstobjective is to induce positive impact andthe way we decide to engage will always be
defined by its effectiveness. Ambitious change
management in large organizations mightprove to be complicated, stressful and evenconsidered impossible by issuers. Adopting
a longer-term view and considering different
intermediate targets for engagement that take
into account situations and circumstances inwhich the company operates is an essential
element of engagement for it to be effective,
keeping the long term goal in mind while seeking
manageable and measurable improvements inthe short to medium term.
As investors we must be both demanding andpragmatic to promote a transition towards asustainable, inclusive and low-carbon economy
in a timely manner. We understand the current
limitations to effectively measure and address
key sustainability themes including climatechange, biodiversity, and human rights.
We consider sustainability to be a moving
benchmark, and as such, our engagement
strategies will evolve overtime to better integratethese developments.

02 Engagement
escalation
When engagement fails or if the remediation
plan of the issuer appears weak, we enact amode of escalation that may lead to exclusion40.
Escalation modes include (in no particularorder) negative overrides in one or several
criteria of the ESG score, questions at AGMs,
votes against management, public statements,
ESG score caps and ultimately exclusion if thematter is critical.
Escalation modes through our voting activities:
if we hold equity in themes that are critical(climate, natural capital preservation including
biodiversity, social and other sustainability
factors or risks, severe controversies and/or
violations of UN Global Compact principles41),
or in case of lack of answers on engagement

40. Refer to “Purpose and Scope” on page 2 for out or partially out of scope affiliates and associated entities of theAmundi Group. For more detailed information on the scope of application of the Exclusion Policy, please refer to the
Appendix at page 35.
41. UNGP (UN Global Compact) https://unglobalcompact.org/

28 Amundi - Global Responsible Investment Policy

related to sustainability factors, Amundi may
decide to vote against the discharge of theboard or management, or the re-election of the
Chairman and of some Directors.
In addition to escalation through our voting
activities, failed engagement might have a
direct impact on the amount of capital allocatedto a company. ESG analysts can downgrade
the related criteria in the ESG score, and if theissue is critical, it could lead to a downgrade of

the overall ESG score. Amundi has committed
to integrate ESG criteria into the investment
process of actively managed open-ended funds,
with an objective to maintain, in addition tofinancial objectives, portfolio average ESG scores
above the average ESG score of the respective
investment universe. Negatively overriding ESG
scores therefore reduces Amundi’s capacity toinvest in the issuer.

29 Amundi - Global Responsible Investment Policy

Reporting &transparency
01 Responsible 		investment assets
under management
reporting
Usually referred to as Amundi’s Responsible
Investment assets under management (RIAUM), this reporting refers to investment
products incorporating responsible criteria
into their investment process. The responsible
criteria relate to specific Environmental, Social
or Governance issues, Ethical or Sustainable
themes42, or to a combination thereof. Dependingon the investment thesis of the product, ESG
characteristics could be assessed through abest-in-class approach (relative ESG rating /scoring approach in relation with issuers’ peers),
or in absolute terms (ESG KPI)43. The responsible
characteristics can be incorporated throughthe exclusion of issuers or activities from an
investable universe, the incorporation of ESG
criteria in investment analysis and decisions tobetter manage risks and returns, or through thepositive screening of best ESG issuers44.
The investment product may promoteresponsible characteristics as a key aspectof its investment process, or among othercharacteristics.
Ultimately, the responsible investment universe
gathers investment solutions with various
responsible approaches in order to address thebroad range of investors’ preferences, amongst
which some of them could be labelled.

An investment product reported in the RI AUM
scope is an investment product applying one ofthose multiple approaches, provided that:➊ it has a responsible investment objective,
either as primary objective or combined withfinancial objectivesor➋ it includes responsible characteristics byintegrating them into the investment decision /selection processor➌ it includes responsible characteristics in order
to exclude issuers from the eligible investment
universeand➍ for products pertaining to the Amundi Global
Responsible Investment policy, the implemented
responsible characteristics are not limited to theAmundi firm wide Global Responsible Investment
Policy, as far as Exclusion, Engagement andVoting policies are concerned.

02 ESG productpolicies

		A. ESG mainstream
products
Amundi’s ESG mainstream investment process
is applied by default to Amundi’s active openended funds45. For each fund, a benchmark

42. For instance related to the Sustainable Development Goals developed by the UN Sustainable Development Goals(https://sdgs.un.org/goals).
43. Usually known as Best-in-class approach or Absolute approach.
44. Usually known as Negative screening, Inclusion, Positive screening.
45. Refer to “Purpose and Scope” on page 2 for out or partially out of scope affiliates and associated entities of theAmundi Group.

30 Amundi - Global Responsible Investment Policy

representative of the investment universe isdefined for that purpose (the ESG benchmark).
Where applicable, the fund needs to have abetter weighted average ESG score than its ESG
benchmark. Many types of products (individual
funds, family of funds, etc.) also have deeper
ESG integration through higher selectivity, rating
or non-financial indicator upgrade, thematic
selection, etc.

Out of scope products
Funds for which the “active management”
component is limited (such as Buy & Watch
funds or securitization undertakings, realestate and alternative funds) as well as funds
not managed on Amundi Investment Platform,
delegated funds or fund hosting products, areout of scope.
Funds with high concentration in Index or limited
rateable issuers coverage are also out of scope.
Please review fund’s offering documents forcomplete information on responsible investment
characteristics.

B. Impact products
Amundi offers impact products. Impact refers
to the positive social and/or environmental
externalities expected from investments.
Impact investments are investments made with
the intention to generate positive, measurable,social and environmental impact alongside afinancial return. Impact is measured in relation
to specific impact goals that have been defined
ex-ante and are based on the intentionality ofinvestors or, where applicable, of the companies
in which they invest.
To qualify impact products, Amundi hasdeveloped an internal impact fund scorecard
that assesses funds alongside three criticaldimensions of impact investing: 1) intentionality,2) measurability, and 3) additionality. Funds
must have a minimum score across all three
dimensions and minimum requirements met in
the Intentionality dimension to be categorized
as Impact products.

46. https://www.impactprinciples.org/
47. https://about.amundi.com/esg-documentation

Amundi is a signatory to the Operating
Principles for Impact Management (the Impact
Principles)46 and Amundi reports on thealignment of its impact management process
for the Impact Principles for all funds that areincluded in its OPIM Disclosure Statement.47

C. Net Zero Ambition
products and Climate
Investment solutions
Amundi recognizes that only a scenario
compatible with the objective to limit global
warming
to
1.5°C
above
pre-industrial
temperatures, with no or low overshoot (i.e.
with limited necessary capture of atmosphericcarbon to bring the temperature back to below
1.5°C) is compatible with the objectives of the2015 Paris Agreement.
Amundi has decided to develop Net Zero
Ambition products. In order to ensure theseproducts are managed in a way that theircarbon footprint follows a trajectory alignedwith carbon neutrality by 2050, Amundi has
set minimum standards for these solutions,
including:– Carbon footprint reduction targets atintermediate dates vs. that of the representative
investment universe in relevant base year,– Minimum exposure to high climate impact
sector to incentivize transition in these key
sectors.
In line with Amundi’s commitment to contributeactively to global carbon neutrality objectives,
Amundi announced in its ESG Ambitions
2025 plan that it would strengthen its level ofcommitment to develop a “net-zero transition”
investment offering. Solutions within thisoffering aim to align carbon emissions reduction
objectives with the objectives set out by theParis Agreement or contribute positively to
climate mitigation or adaptation objectives(“Climate Investment solutions”).

31

Amundi - Global Responsible Investment Policy

Climate investment solutions, which aim tocontribute positively to climate mitigation
or adaptation objectives, need to meet thefollowing criteria:– Have an intention to contribute: by investing
into projects or companies that are associatedwith the development of positive climate
solutions linked to adaptation or mitigation
objectives (captured by the French Greenfin
Label48, sustainable investment objectives
outlined in the investment policy (SFDR
Article 949), and/or impact classification as per
Amundi Impact Products Guidelines50);– With a main focus on climate change: areclassified as “Green Alternative Assets”,“Green Bonds” or “Green Equity” strategies,
as per Amundi internal product classifications.

Our offer is locally adapted locally for retailcustomers, distributors and other professionaland non-professional investors. Among our
responsible solutions, we offer a range of
products that have received the following labels(non-exhaustive list):– SRI, Greenfin and FAIR (ex Finansol) in France,– FNG in Germany,(ex-Febelfin)

Amundi also complies with the European
Transparency code. This code is designed
and approved by AFG, FIR and EUROSIF51
and provides for transparent and precise
information on responsible investment portfolio
management from asset managers to clients.

To reinforce its transparency towards investors,
Amundi periodically sends comprehensive
commented reports to its institutional clients.

LabelsSustainability

Amundi has the ambition to publish ESG
reports on responsible investment open-ended
funds every month. These reports include a
comparison of the portfolio’s ESG rating withthat of its benchmark index or investment
universe, as well as comments on the ESG
performance of the portfolio’s issuers.

Specific reporting is published on certain
thematic funds from our climate and solidarity
ranges to ensure accurate impact monitoring.

03 Labels andtransparency of
information– Towards
Belgium,

Transparency of information at
fund levelinTransparency of information at
asset management company
level
Amundi reports on its corporate responsible
investment activities on a yearly basis through:– A stewardship report,– A voting report complemented by online
access to proxy voting records,– An engagement report,– A climate and sustainability report.

– LuxFlag in Luxembourg,– Austrian Ecolabel in Austria.

48. As a result of the discussions that took place at the Banking and Finance Conference on Energy Transition of June2014 a label was created to specifically identify investment funds contributing to the energy and ecological transition. The
creation of such a label is one of the public policies called for by Article 2 of Energy Transition for Green Growth Law ofAugust 2015. Its creation has been guided by a desire to promote «green» funds in order to further steer savings towards
energy and ecological transition and the fight against climate change, either by drawing attention to existing investment
funds or by giving rise to the creation of such funds. It is a guarantee, for investors and individual savers in particular,of the quality and transparency of the environmental characteristics of the funds distinguished in this way and of theircontribution to the energy and ecological transition and the fight against climate change. As a public label, the Greenfin
Label must be ambitious. In addition, although covered by French legal standards, this label can be applied to financial
funds from other countries in the European Union or non-member countries. For more information please refer to theGreenfin Label guidelines: https://www.ecologie.gouv.fr/sites/default/files/Label_TEEC_Criteria%20Guidelines.pdf
49. Sustainable Finance Disclosure Regulation
50. See above.
51. Forum pour l’Investissement Responsable (FIR), Association française de la gestion financière (AFG), European
Sustainable Investment Forum (EUROSIF).

32

Amundi - Global Responsible Investment Policy

At the same time, Amundi conducts responsible
finance trainings for its employees, for thefinancial advisors of its partner distribution
networks and at the request of its clients.

04 EU regulatory
information
Information related to the implementationin Amundi of Regulation (EU) 2019/2088 on
sustainability-related
disclosures(“SFDR”)
and Regulation (EU) 2020/852 on theestablishment of a framework to facilitatesustainable investment (‘Taxonomy Regulation’)
may be found in Amundi’s Sustainable Finance
Disclosure Statement available here.
For
product-levelsustainability-related
disclosures please refer to the relevant Amundi
website or prospectus.

33 Amundi - Global Responsible Investment Policy

Advancing theasset management
industry
01 Active participationin market bodies
Amundi actively participates in working groups
led by market organisations aimed at developing
responsible finance, sustainable development
and corporate governance. Amundi is a memberof (non-exhaustive list): the French AssetManagement Association (AFG); the European
Fund and Asset Management Association(EFAMA); the French Observatory for Societal

Responsibility(ORSE);
theSustainable
Investment Forums (SIF) in France (Forumpour l’Investissement Responsible - FIR), Spain(Spainsif) and Sweden (Swesif); the Canadian,Japanese and Australian SIFs; and the French
association Companies for the Environment(EPE). Amundi is also a member FAIR52.
In July 2021, Amundi joined the Net Zero AssetManagers initiative, committing to support thegoal of net emissions by 2050 or sooner.

52. Financer Accompagner Impacter Rassembler (ex FINANSOL) FAIR is a French association that unifies different
stakeholders of social impact finance in France

34 Amundi - Global Responsible Investment Policy

The table below lists the principles Amundi adheres to, the statements we have signed and themarket bodies we participate in.
– PRI - Principles For Responsible Investment– UN Global Compact– IFD – Institut de la Finance Durable– GIIN Operating Principles for Impact Management

Responsible
Investment– GISD – Global Investors for Sustainable Development Alliance– High-Level Expert Group on Scaling up Sustainable Finance in Low and Middleincome countries– WBA - World Benchmarking Alliance– EUROSIF – European Sustainable Investment Forum– GIIN – Global Impact Investing Network– CASI – Capacity-building Alliance of Sustainable Investment– NZAM - Net Zero Asset Managers– IIGCC - Institutional Investors Group on Climate Change– AIGCC - Asia Investor Group on Climate Change– CDP - Disclosure Insight Action– ICMA - Green Bonds Principles– CBI - Climate Bonds Initiative

Environmental– Climate Action 100+
– TCFD - Task Force on Climate-related Financial Disclosures– The Japan TCFD Consortium– OPSWF - One Planet Sovereign Wealth Fund
– FAIRR - Farm Animal Investment Risk and Return– Finance for Biodiversity Pledge– Nature Action 100– Access to Medicine Index– Access to Nutrition Index– ICMA - Social Bonds Principles– WDI - Workforce Disclosure Initiative– FAIR - Financer Accompagner Impacter Rassembler (ex Finansol)

Social– PLWF - The Platform Living Wage Financials– Investors for a Just Transition– Investor Action on Antimicrobial Resistance– The 30% Club France Investor Group– The 30% Club Japan Investor Group– The 30% Club Germany Investor Group– Tobacco-Free Finance Pledge

Governance– ICGN - International Corporate Governance network– CII - Council of Institutional Investors

02 Academic support
Amundi actively supports academic researchand has formed several partnerships with
university chairs on climate finance. In early
2023, Amundi increased its support to leading
research initiatives on climate change mitigation
and adaptation by sponsoring three research
initiatives: the “Measuring and Managing

Climate Risks in Investment Portfolios” researchchair at EDHEC-Risk Climate Impact Institute,
OS-Climate by the Linux Foundation, and the
MIT Joint Program on the Science and Policy of
Global Change.

35 Amundi - Global Responsible Investment Policy

Appendix
Exclusion Policy Scope of Application53
TABLE 1: Exclusion Policy scope of application by asset class54
Antipersonnel
mines andclusterbombs

Asset Class

Active Funds

Chemical,biologicaland depleted
uranium
weapons

Open-ended
funds

UN Global
Compact
Principles

NuclearWeapons

Passive Funds

ThermalCoal

Unconven-tionalFossil Fuel

AppliedAppliedNon-ESGETFs andindex funds

TobaccoNot applied

For non-ESG passive funds: The fiduciary duty in passive management is to
replicate as closely as possible an index. The portfolio manager has thus limited
leeway and has to meet the contractual objectives to get passive exposure fullyin line with requested benchmark. Amundi index funds/ETFs replicating standard(non- ESG) benchmarks cannot apply systematic exclusions.
AppliedESG ETFs
and index
funds

FormulaFunds

New funds(SinceOctober
2021)
Former funds

Buy & Watch
Funds

Multi
Management

Fund Hosting

Sub-Advisory

ESG synthetic ETFs, the securities held in the substitute basket fully comply
with Amundi’s Exclusion Policy. The methodology of the underlying indices aredesigned and calculated by their respective index provider according to their own
ESG data set and this might lead to some discrepancies of assessment compared
to Amundi global ESG rating.

AppliedAppliedApplication of the Exclusion Policy in force at the
inception date of the funds

AppliedApplication of the Exclusion Policy in force at the
inception date of the funds

Funds
of funds(“wrappers”),
external
funds

See section “External fund selection and monitoring”

Amundicontrolled
Funds

AppliedOther
investment
funds

Not applied

Fund
Channelfunds

Applied53. Refer to “Purpose and Scope” on page 2 for out or partially out of scope affiliates and associated entities of theAmundi Group. Please review a Fund’s offering documents for complete information on ESG integration.
54. For any new mandate or dedicated fund, Amundi’s Exclusion Policy shall be implemented in accordance with our precontractual documentation, unless otherwise requested by a client.

36 Amundi - Global Responsible Investment Policy

TABLE 2: Exclusion Policy scope of application by instrument55
Anti-personnelmines
and cluster
bombs(Ottawa andOslo treaties)

Chemical,biologicalanddepleteduranium
weapons

UN Global
Compact
Principles

NuclearWeapons

Equities

AppliedSecurities held directly

AppliedSingle name derivatives

AppliedIndex derivatives

Not applied

TobaccoThermalCoal

Unconven-tionalFossil Fuel

AppliedSecurities received ascollateral43

This includes securities received in the context of securities lending transactions or overthe counter (OTC) transactions, as well as repurchase agreements in exchange for cash
placed on the other hand. Securities received that rated G by Amundi are sent back to
the counterparty (ex post).

Convertibles

AppliedCash instruments

Applied55. Refer to “Purpose and Scope” on page 2 for out or partially out of scope affiliates and associated entities of theAmundi Group. Please review a Fund’s offering documents for complete information on ESG integration.

37

Amundi - Global Responsible Investment Policy

TABLE 3: Exclusion Policy scope of application by type of exclusion56
Category

Weapons (all but
nuclear weapons)

Nuclear weapons

1/2

Sub category

Nuclear Weapons

Nuclear Weapons

Anti-personnel mines andcluster bombs57

Issuers involved in the production,
sale, storage or service

first €1 of revenue

Chemical and biologicalweapons58

Issuers involved in the production,
sale or storage

first €1 of revenue

Depleted uranium
weapons59

Issuers involved in the production,
sale or storage of depleted
uranium weapons.

first €1 of revenue

Issuers involved in the production,
sale, storage of nuclear weaponsof States non-Party to the Treaty
on the Non-Proliferation of
Nuclear Weapons and of States
signatories of the Treaty on NonProliferation of Nuclear Weapons
but not members of NATO

first €1 of revenue

Issuers involved in the productionof nuclear warheads and/or
whole nuclear missiles as well ascomponents that were developed
and/or significantly modified for
exclusive use in nuclear weapons

first €1 of revenue

Companies that derive significant
revenue from the production orsale of nuclear weapons, excluding
revenues from ownership anddual use components as well asdelivery platforms>5% of total revenues

Companies involved in
the production of corecomponents of the nuclear
weapon or dedicatedcomponents.
Issuers are considered
for exclusion if they meetat least one of the threefollowing criteria:

UN Global Compact principles

Exclusion of issuers that violate, repeatedly and seriously, one
or more of the ten principles of the Global Compact, without
credible corrective action

56. Refer to “Purpose and Scope” on page 2 for out or partially out of scope affiliates and associated entities of theAmundi Group. Please review a Fund’s offering documents for complete information on ESG integration.
57. Conventions Ottawa 3/12/1997 and Oslo 3/12/2008, ratified by 164 and 103 countries respectively as of July 2018
(including European Union countries and excluding the United-States).
58. Convention on the Prohibition of the Development, Production, Stockpiling and Use of Chemical Weapons and on
their Destruction 13/01/1993 and Convention on the Prohibition of the Development, Production and Stockpiling ofBacteriological (Biological) and Toxin Weapons and on their Destruction 26/03/1972
59. Although not subject to a ban or restriction by international treaty, depleted uranium is often considered ascontroversial weapon.

38 Amundi - Global Responsible Investment Policy

TABLE 3: Exclusion Policy scope of application by type of exclusion

Developers

Mining extraction
Thermal coal60

Companies considered
too exposed to be able tophase out from thermal
coal at the right pace

2/2

Mining companies, utility
companies, and transport
infrastructure companies that aredeveloping coal projects with apermitted status and that are in
the construction phase.

Not part of the active
investment universe

Companies with a % of revenues inthe thermal coal extraction>20% of revenues

Companies with thermal coal
extraction of X MT or more
without intention to reduce

70 MT or more

Companies that derive more thanx% of revenues from thermal coalmining and thermal coal power
generation>50% of total revenues

Companies that derive between
X% and Y% of revenues fromthermal coal-based electricity
generation and thermal coalmining, with a poor transition
trajectory

Threshold between 20%
and 50% of total revenues

Unconventional
fossil fuels: shaleoil, shale gas andoil sands

Companies exposed to exploration and production of
unconventional oil & gas (covering shale oil, shale gas and oilsands)>30% of revenues

TobaccoCompanies that manufacture complete tobacco products,
including cigarette manufacturers>5% of revenues

Investee countries
subject toviolations

Countries on the European Union (EU) sanction list with asanction consisting of asset freezing, and a sanction index at thehighest level (considering both United States and EU sanctions)Exclusion after formal
review and validationfrom Amundi’s Rating
Committee

60. 100% of "coal" companies under exclusion thresholds and invested by Amundi are committed in order to obtain an exit
plan and an escalation plan is triggered if the commitment proves unsuccessful within the compatible 2030 OECD / 2040Non OECD timetable.

39 Amundi - Global Responsible Investment Policy

A long-standing player in ESG integration
In 2010, Amundi chose commitment to social
responsibility as one of its four founding
pillars, meaning that we take increasingly into
account sustainable development and socially
responsible criteria as well as financial criteria in
our investment policies.

In 2017, Amundi launched the largest green
bond fund dedicated to emerging markets ($2billion) in partnership with the International
Finance Corporation (IFC), to accelerate thedevelopment of the green bond market inemerging markets development economies.

In 2011, Amundi incorporated its subsidiary
IDEAM in its Institutional Investments division inorder to streamline its organisation and better
serve its growth ambitions in the field of socially
responsible investment (SRI).

In 2018, Amundi expanded its commitment
to responsible investment and announced,
in October, a three-year Action Plan withthe ambition of integrating ESG into 100%of its open-ended funds and in all its voting
practices. Amundi also aimed to develop its
advisory services and to strengthen specificenvironmental, social and solidarity initiatives.

In 2013, Amundi was the first asset managementcompany to obtain Afnor certification for its
SRI approach. This certification, delivered by arecognised independent organisation, proves
our commitment to our clients (governancemethod, guaranteed expertise, data traceability,
information, responsiveness, etc.) while ensuringthat our operations are controlled by an internal
steering process.
In 2014, Amundi published its first Engagement
Report.
In 2015, Amundi ranked first in the SRI &Sustainability study published by WeConvene
Extel and the UKSIF (UK Sustainable Investment
and Finance Association), in the category AssetManagement best firms for SRI/ESG.
In the same year, Amundi was very active infinancing the energy and environment transition
beyond its participation in the main Green
Bonds Initiative and its signature of the Paris
Green Bonds Statement.
In 2016, Amundi became the first asset
management company to obtain the SRI label
created by the Ministry of Finance and Public
Accounts for its four presented funds. This SRI
label aims to provide better visibility of SRI fundofferings to investors, particularly individual
customers who are showing a growing interest
in SRI.
In the same year, Amundi was once again ranked
N°1 in SRI & Sustainability study published
by Extel and UKSIF in the category AssetManagement best firms for SRI/ESG.

In December, Amundi Energy Transition (AET),a subsidiary of Amundi (60%) and EDF (40%)
and Dalkia (EDF group) signed a partnershipagreement to finance energy transition projects.
Amundi expanded its range of responsible
solutions with the launch of new innovative
products through its subsidiary CPR AM andvia its range of ETFs dedicated to responsible
investment.
In 2019, Amundi continued to implement its active
policy by developing responsible investment,
illustrated by innovations such as the launch of a
new climate bond fund to finance infrastructurein emerging countries, in partnership with the
Asian Infrastructure Investment Bank (AIIB),
and the launch of the Green Credit Continuum
programme with the European Investment Bank
(EIB) aimed at promoting the development of
the green debt market in Europe, particularly byfinancing SMEs.
This engagement was also reflected in Amundi’s
participation in the One Planet Sovereign
Wealth Fund Asset Manager initiative, designed
to support sovereign wealth funds in integratingclimate change into the management of theirinvestments; and participation in the TCFD
Consortium initiative in Japan under the aegis
of the Japanese Ministries of the Economy
and the Environment, designed to improve theinformation provided to issuers on environmental
issues.

40 Amundi - Global Responsible Investment Policy

In 2020, after having supported the expansionof green bonds in emerging markets, Amundi
also committed to support the developmentof Social Bonds and launched in December its
first Social Bond Strategy. Additionally, Amundiannounced the launch of the Objectif Climat
Actions strategy, replicating the “Euro iSTOXX
Ambition Climate PAB” index. In parallel, our ETF
department expanded its Responsible Investing
ETF range, proposing a comprehensive set of
equity and fixed income ESG and Climate ETFs,
spanning across key investors’ geographiesand proposing different levels of sustainability
integration.
In 2021, Amundi joined the Net Zero AssetManagers Initiative, committing to support
the goal of net emissions by 2050 or sooner,
and announced its ESG Ambitions 2025 plan,
outlining 10 objectives to accelerate Amundi’s
responsible investment transformation in
its investment and saving solutions, in its
engagement with investees, and by acting
responsibly as a corporate.
In 2022, Amundi announced its inaugural Net
Zero Asset Managers Initiative intermediatetarget.

41

Amundi - Global Responsible Investment Policy

DISCLAIMER
This document is not intended for citizens or residents of the United States of America or to any“U.S. Person”, as this term is defined in SEC Regulation S under the U.S. Securities Act of 1933.
This material is communicated solely for information purposes and neither constitutes an offer tobuy, an investment advice nor a solicitation to sell a product. This material is neither a contract nor
a commitment of any sort.
The information contained in this material is communicated without taking into account the specificinvestment objectives, financial situation or particular need of any particular investor.
The provided information is not guaranteed to be accurate, exhaustive or relevant: although it has
been prepared based on sources that Amundi considers to be reliable it may be changed without
notice. Information remains inevitably incomplete, based on data established at a specific time andmay change.
All trademarks and logos used for illustrative purposes in this document are the property of theirrespective owners.
Amundi accepts no liability whatsoever, whether direct or indirect, that may arise from the use of
information contained on this material. Amundi can in no way be held responsible for any decision
or investment made on the basis of this information.
Investment involves risk. Past performances and simulations based on these, do not guarantee
future results, nor are they reliable indicators of futures performances. The information contained inthis material shall not be copied, reproduced, modified, translated or distributed without the priorwritten approval of Amundi, to any third person or entity in any country or jurisdiction which would
subject Amundi or any of its products, to any registration requirements within these jurisdictions or
where it might be considered as unlawful.
The information contained in this document is deemed accurate as of November 2023.

LEGALS
Amundi Asset Management
French “Société par Actions Simplifiée” - SAS with a capital stock of 1 143 615 555 euros - Portfolio
management company approved by the French Financial Markets Authority (Autorité des Marchés
Financiers) - under no. GP 04000036.
Head office: 91-93 boulevard Pasteur, 75015 Paris - France.
Postal address: 90 boulevard Pasteur, CS 21564, 75730 Paris Cedex 15 - France.
Tel : +33 (0)1 76 33 30 30 - Website : www.amundi.com - Siren no. 437 574 452 RCS Paris - Siret no.
43757445200029 - APE code: 6630 Z - VAT identification no. FR58437574452.