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Stewardship Report 2021

Stewardship Report2021
October 2022

October 2022

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Stewardship Report 2021

October 2022

Preface

Stewardship is central toAmundi’s Responsible
investing approach“Amundi’s robust stewardship policy andtargeted focus on society’s key global challenges
defines its responsible investment practices.
We use the Paris Agreement framework to
inform and challenge our business strategy andrelationship with investee companies. As active
stewards, Amundi relies on its influence andscale to deliver real world impact. ESG risks andopportunities are integrated in our engagement
strategy, investment decisions, and voting
activities. We also collaborate on an industrywide level to lead change and create common
standards. We believe these actions not only
drive long-term value for our clients’ portfolios,
they provide an impetus for positive change inour society.

Over the last years, we have reinforced our
engagement efforts especially with climatechange, natural capital preservation, social
cohesion and equality. Although we were alreadyconvinced that the environmental and social
dimensions of ESG have an economic impact,
the recent geopolitical events and repetitive
climate extreme events are more indicators ofthe magnitude those impacts could reach. In
this context, we welcome the reinforcement
stewardship activities among investors, thedevelopment of Stewardship Codes aroundthe world, and the recommendation of the
Shareholder Rights Directive II that each
European Union country should have its own
such Code.
This report is organised according to theprinciples of the UK Stewardship Code but intends
to set out our response to the requirements ofa number of different Stewardship Codes. As an
appendix, we provide a guide to how this reportdelivers on the expectations of the EFAMA
Stewardship Code, and the relevant codes andprinciples for Australia, Canada, Italy and Japan.”Jean-Jacques Barbéris

Executive Committee Member,Head of ESG

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Contents
PREFACE..........................................................................................................................................................................................2
PURPOSE AND GOVERNANCE
PRINCIPLE 1....................................................................................................................................................................................5
1. Responsible investing at Amundi: our philosophy, investment beliefs and approach...........................5
2. Responsible investing at Amundi: our strategy........................................................................................................7
PRINCIPLE 2.................................................................................................................................................................................12
1. How our structure supports and enables responsible investingand stewardship deployment........................................................................................................................................... 12
2. A dedicated internal organisation to monitor and manage
the responsible investment strategy........................................................................................................................... 13
3. A dedicated Responsible investment team............................................................................................................. 15
4. External research providers, an essential resource.............................................................................................20
5. Incentives and ESG............................................................................................................................................................. 23
PRINCIPLE 3................................................................................................................................................................................25
1. Amundi’s relationship with Crédit Agricole.............................................................................................................. 25
2. Avoiding conflicts of interest in stewardship activities.....................................................................................26
3. Other specific initiatives to avoid conflicts of interest....................................................................................... 27
PRINCIPLE 4...............................................................................................................................................................................29
1. Rigorous risk management to frame our activities..............................................................................................29
2. Promoting good practices through risk-management related innovation and coalition..................33
PRINCIPLE 5................................................................................................................................................................................38
1. Review and assurance of our ESG approach..........................................................................................................38
2. A three level control process on ESG topics..........................................................................................................38
3. Dedicated control of data................................................................................................................................................39
INVESTMENT APPROACH
PRINCIPLE 6................................................................................................................................................................................41
1. Tailoring our approach to client needs........................................................................................................................ 41
2. Reporting openly and transparently to our clients.............................................................................................47
3. An external certification to ensure the quality of our key internal processes
and reporting capabilities................................................................................................................................................47
PRINCIPLE 7................................................................................................................................................................................48
1. ESG analysis consolidates value creation.................................................................................................................48
2. A proprietary ESG rating available to all portfolio managers........................................................................49
3. ESG analysis and rating across asset classes.......................................................................................................... 51
4. Exclusionary approach......................................................................................................................................................59
5. Enhancing integration of ESG considerations into investment activities:
2021 ambitions and climate developments.............................................................................................................62

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PRINCIPLE 8............................................................................................................................................................................... 64
1. Data providers........................................................................................................................................................................64
2. Proxy advisors.......................................................................................................................................................................66
ENGAGEMENT
PRINCIPLE 9...............................................................................................................................................................................67
1. The aims of engagement.................................................................................................................................................. 67
2. The nature of engagement..............................................................................................................................................68
3. The 2021 Campaign.............................................................................................................................................................79
PRINCIPLE 10.............................................................................................................................................................................92
1. Collaborative engagement: working with our peers to help drive the conversation...........................92
2. Collaborative engagement: involvement of Amundi in industry bodies...................................................93
3. Illustrations of collective actions in which Amundi has been involved...................................................... 97
4. Support for research into responsible investment matters.......................................................................... 105
PRINCIPLE 11.............................................................................................................................................................................107
1. Measuring and monitoring engagement progress............................................................................................. 107
2. Engagement escalation: to have an impact we need to incentivize change
when momentum is slow................................................................................................................................................ 107
EXERCISING RIGHTS AND RESPONSIBILITIESPRINCIPLE 12............................................................................................................................................................................. 112
1. Our vision of exercising voting rights.........................................................................................................................112
2. Amundi’s voting policy......................................................................................................................................................113
3. Scope of the voting policy............................................................................................................................................. 114
4. Exercising our voting rights in a considered and responsible manner......................................................115
5. Questions in AGMs & voting against management as an escalation mode...........................................116
APPENDIX:................................................................................................................................................................................. 122– ESG policies and reports, ESG Reporting.................................................................................................................122– Delivery against the expectations of other stewardship codes.................................................................... 128

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PURPOSE AND GOVERNANCE

Principle 1
Signatories’ purpose, investment beliefs, strategy, andculture enable stewardship that creates long-term value forclients and beneficiaries leading to sustainable benefits forthe economy, the environment and society

1. Responsible investing at Amundi: our philosophy,
investment beliefs and approach
Amundi is a leading European asset manager with EUR 2.1 trillion managed on behalf of clientsas of 31 December 2021. Amundi’s mission is to be a trusted partner that acts every day in theinterest of its clients and society. Our ability to earn the trust of a wide variety of private andinstitutional investors all over the world has led us to have a global client base of over 100 million
retail clients through our distribution partners, as well as over 1,300 direct institutional andcorporate clients.

a. A broad geographical and asset class basis
Graph 1: Amundi’s AUM by asset class and geography
Full range of asset classes

Real, alt.
and structured
assets6%

Multi-asset
17%

Treasury
products
11%International presence
Passive
Management
17%

Equities
25%

Rest of theWorld 6%

Asia 18%

Breakdown of AuM
by asset class(31/12/2021)

Breakdown of AuM
by geography(31/12/2021)
Europe excl.
France & Italy
17%

ActiveManagement
65%

Bonds
14%

Italy 10%

As of December 2021, including Lyxor

France 48%

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b. Responsible investing: a founding pillar of Amundi’s investment
philosophy
Amundi Asset Management is 70% owned by
Crédit Agricole (CA), France’s largest bank andinsurer. CA was founded by French farmers asa cooperative and a mutual financial institution
more than a century ago. We are proud of thisheritage, which makes it natural for Amundi tothink first of clients’ best interests and to be
responsive to social needs and the environment.

Amundi’s culture is nourished by four sharedvalues: Courage, Team spirit, entrepreneurial
spirit and Solidarity, influencing individualand collective behaviour.

“In a non-stationary world,
Investment theory is a
support not a dogma”
Economic and financial
models as well assustainability risk models
should be used with a clear
awareness of their underlying
assumptions“Risk is multi-faceted”
Risk goes beyond market
risk to encompass otherdimensions such as liquidity
risk, credit risk, sustainability
risks or reputational risk

We believe that our role is to deliver long-termvalue for our clients while being conscious of
the needs of the world around us. Responsible
Investment was set out as one of the four
founding pillars of Amundi since its inception in2010 and it continues to be a key component of
our strategy. This commitment is reflected bothin our management process, in the solutions
range Amundi has developed, and the advisory
capabilities we deploy to help clients define andimplement their own approach.
Our core investment beliefs are founded on theunderstanding that long-term and sustainablesuccess lies in collective effort and soundprocesses. Those beliefs are:“Only a prepared mind canreact”
Investment requires theadaptation of widelyaccepted assumptions
and the ability to processeconomical, geopoliticaland sustainability factors tonavigate increasingly frequent
markets disruptions andparadigms’ changes“Value creation goes beyond
performance”
Being asset owners
and managers brings
responsibilities“Investing for the long term is
an advantage”
Investing over the long termallows to capture sources ofgrowth such as risk premia
or sustainability-linked
innovation“Optimality is not universal”
Opportunities should beassessed within the investor’scontext and sustainability
preferences“Long-term & sustainablesuccess lies in collective effort& solid processes”
Teamwork and idea crossfertilization are sources ofadded valuec. What we believe acting as a responsible investor means
Amundi’s approach to responsible investing lieson three main convictions:• Economic and financial players bear asocietal responsibility;• The integration of Environmental, Social andGovernance dimensions in investment choices
is a source of long-term performance;• ESG will be a growth driver for Amundi
worldwide.

A true industrial revolution is required tosuccessfully transition our economies to a moresustainable, low-carbon, and inclusive model.
This can only be done if the major players governments, businesses, and the larger financial
system - are aligned. Governments must redefine
public, industrial and fiscal policies and coherent
regulations, whereas businesses must develop
the necessary technological solutions, and thefinancial system must support companies by
allocating the capital necessary to achieve theseobjectives.

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We acknowledge that it is our responsibility tosupport efforts to address systemic problems
and to effectively allocate capital for the future.
As a major shareholder in several companies via
the funds and mandates we manage on behalfof its clients, we particularly believe that it is
our responsibility to encourage and accelerate
the transition of companies towards a moresustainable model.

“Amundi firmly believes that companies
and investors have a responsibility tosupport a transformation of the economy
and society towards more sustainablemodels and that the integration of ESG
issues has a positive impact on long-term
financial performance, due to the strategic
management of risks and opportunities
associated with these issues”.

2. Responsible investing at Amundi: our strategy
a. From philosophy to actions
As a result of these convictions and beliefs,
Amundi has made a commitment toincorporating ESG factors into its investment
processes as well as supporting a sustainabletransition through its ambitious engagement
policy, the development of sustainable capital
markets, and the mobilization of capital on a
global scale since its creation in 2010.
This strategy is integrated within various asset
management activities in Amundi thanks
to: policies governing asset exclusion, ESG
integration into investment process and voting
activity as well as through the range of dedicatedresponsible solutions and services that Amundi
has developed.

Having dedicated resources enables the
deployment of our responsible investment
strategy, by ensuring on one side common
principles and standards across Amundi
responsible investment solutions’ range, andon the other, the ability to customize solutions
and services to the various ESG preferencesof our clients. Having proprietary ESG rating
methodology and fundamental qualitative
ESG research capabilities are key pillars of ourstrategy, to ensure our actions are consistent
with stated beliefs and convictions. The
significance given to ESG and climate change
issues is reflected in ambitious action plans, the2018 – 2021 ESG plan achieved in 2021 and the
new “Ambition 2025”plan, currently underway.

Illustration 1: Amundi's key commitments of the past 20 years

2004

Member of the
CDP (formerly
Carbon Disclosure
Project)

Signatory of the
Principles for
Responsible
Investment (PRI)

2006

2014

• Amundi joins the
Finance for Tomorrow
initiative• Launch of thelargest green bondfund dedicated toemerging markets
with IFC1

Development of low
carbon indices withMSCI on behalf of AP4
and FRR

2017

2018

Innovation in
Sustainable FinancePartnerships with the
EIB2 AND the AIIB3Amundi launches a fullrange of SRI equity
and bond ETFs

2019

2021

• Amundi joins
the Finance for
Biodiversity Pledge• Joining the Net
Zero Asset Managers
initiative• 847 billion in
Responsible
Investment assets4

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➜ Our progress in 2021

✔ In July 2021, Amundi confirmed the strategic importance of tackling climate change andfinancing a just transition by announcing its membership in the Net Zero Asset Managers
initiative (see Principle 4)✔ As an active member of this initiative, Amundi spoke on behalf of the Finance for Biodiversity
Pledge and the financial sector during the High Level Segment of the 15th UN Conference on
Biodiversity (COP 15).

✔ In 2018, Amundi set out a three-year action plan to implement a responsible investment
approach across its entire product platform. In December 2021, Amundi announced the 20182021 ESG plan’s achievements.

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Illustration 2: Achievements of the 2018-2021 ESG plan
The plan was concluded in December 2021 with all key objectives met.

In terms of its savings and investment solutions:• ESG criteria have been integrated into all actively managed open-ended funds, with the aimof achieving a higher ESG rating than the benchmark1;• Responsible investment assets under passive management reached some EUR95 billion2
thanks to the development of a dedicated ESG and Climate offer;• Assets dedicated to specific initiatives promoting energy transition or social cohesion3
reached EUR34.8 billion, supported in particular by several innovations to support energy
transition in emerging markets and through private-assets.
• The Amundi Solidarité fund, deployed EUR440 million4 in the social and solidarity economy,
and is the largest solidarity fund in France;• Amundi developed an ESG advisory offering dedicated to institutional investors anddistributors to support them in their ESG transition.

In terms of its actions with businesses:• Environmental and social issues have been systematically considered in discussions withissuers and in how voting rights are exercised. Amundi voted at more than 7,300 General
Meetings and engaged in dialogue with nearly 1,033 businesses on issues such as the transition
to a low-carbon economy, preserving natural capital, social cohesion, sound governance, andso on.
As of end of December 2021, thanks to the plan’s rollout, Amundi held almost EUR 850 billion
in Responsible Investment assets, compared to EUR378 billion as of end of 2020.
As part of this 2018-2021 ESG plan implementation, Amundi created training and knowledgetransfer programs to help support clients on their journey to progressively implement ESG
considerations in their investments
In December 2021, Amundi presented a new ESG strategic plan for the 2022–2025 period,
strengthening its ambitions to support a fair environmental transition. Amundi’s new action
plan aims to increase its commitments through the savings and investment solutions offeredto its clients, actions taken to assist businesses, and measures to align its employees with its
new ambitions.

Illustration 3: Clients' trainings campaign• 94 seminars, training sessions, and meetings took place in 2021, for over 100 institutional
clients reaching more than 1,200 professional investors.
• 16 seminars, trainings, and meetings, were held with private banking clients and other
distributors, reaching more than 18,500 retail investors.

1. Scope of active open funds, where technically feasible
2. The objective of doubling the responsible investment assets held in passive management published as of 8 October2018
3. The objective of doubling the assets dedicated to specific initiatives promoting energy transition or social cohesion
published as of 8 October 2018
4. Objective of EUR500 million as of 31 December 2021

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Illustration 4: Release of the new “Ambition 2025” plan
Amundi “Ambition 2025” plan comprises ten key measures: Amundi’s new ESG action
plan aims to increase its commitments through the savings and investment solutions offeredto its clients, actions taken to assist businesses, and measures to align its employees with its
new ambitions.
In terms of its savings or technology solutions offering, by 2025 Amundi commits
to:1. Incorporate a new environmental transition rating into its open-ended active management
funds that have an ESG performance target. This rating will be used to assess businesses basedon their decarbonisation efforts and the development of their green activities. The portfolio’s
stated objective of the portfolios in question would be to have a better environmental transition
profile than their reference investment universe;
2. Offer open-ended funds with a “Net-Zero 2050” investment objective across all major asset
classes;
3. Reach EUR20 billion in impact funds that will invest in businesses or finance projects that
seek to achieve positive environmental or social performance;
4. Have 40% of its range of ETF passively managed funds made up of ESG funds;
5. Develop Alto Sustainability, within Amundi Technology, a technological solution to aid
analysis and decision making for investors on environmental and societal issues.

In terms of its actions targeting businesses, Amundi commits to:
1. Include 1,000 more companies within the scope of businesses with which it engages inan ongoing climate dialogue, aimed at defining credible strategies to reduce their carbon
footprint, to ensure these are voted on at general meetings, and to ensure their executives
commit part of their remuneration to these strategies;
2. Exclude as of 2022 all companies that conduct more than 30% of their business in nonconventional oil and gas sectors from its investments5.

In order to align its employees and shareholders with this new ambition, Amundi
resolved to:
1. Reduce its direct greenhouse gas emissions by nearly 30% per employee in 2025 compared
to 2018;
2. Index 20% of the compensation of its 200 senior executives to the achievement of its
responsible investment objectives and to set ESG objectives for all its managers and salespeople;
3. Present its climate strategy at the next General Meeting in 2022 to its shareholders.

b. Engagement & Voting, a key pillar of our strategy.
To learn more, please refer to Principle 9 to 12.
Stewardship activity is central to Amundi’s
responsible investing philosophy, as it plays a
key role in enabling a wide transition towards
a sustainable, inclusive low carbon economy.
In addition to the systematic integration of
ESG criteria in our active investments.
Amundi has developed an active stewardship
activities through engagement and voting.

As one of the main shareholders for someinvestee companies, Amundi has a role to playin driving capital towards the leading actors
in ESG and in influencing laggards so thatthey modify their strategies relatively to theseissues. This is why stewardship is central to
our Responsible Investing strategy, and to ouroverall investment philosophy. We recognise

5. Oil sands, shale oil and shale gas.
This targeted exclusion policy will be implemented in 2022 across the same scope as Amundi’s other sectoral exclusion
policies (active management strategies where Amundi has full portfolio management discretion, and ESG ETFs except for
highly concentrated indices).

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that we are part-owners of the companies inwhich we invest and that we have an obligation
to influence their strategies towards approaches
that more effectively take account of ESG
issues more effectively. We seek constructive
dialogue to help drive change by laggards, andto support those which are already delivering
positive results.

Our voting activity is an integrated arm of ourstewardship activities. Insufficient improvements
following an active engagement could trigger anegative vote. Engagements are also triggeredby our voting activity to encourage issuers andissuers’ boards to better integrate sustainability
and long-term views in their company’s strategicplanning.

Our pro-active engagement policy seeks to:– Contribute to best practice disseminationand drive a better integration of sustainability
in companies’ governance, operations andbusiness models

Our voting policy makes best use of our duties
as part-owners of issuers that emphasize theneed,– For an accountable, diversified & wellfunctioning board– Trigger positive change concerning how
companies are managing their impacts
on specific topics that are paramount tothe sustainability of our society and of oureconomy,– For corporates’ governance and boardthat grasp the environmental and social
challenges,– Support companies in their own transition
towards a more sustainable, inclusive and low
carbon business model– Engage to push issuers to increase their levelof investment in Capex/R&D in highly needed
areas for this transition– To ensure that boards & corporates areappropriately positioned and prepared tohandle the transition towards a sustainable,
inclusive low carbon economy
We believe that engagement and voting will play
an even greater role going forward and alreadyforms a key pillar of our “Ambition 2025” plan.
Amundi’s ambition is to scale up the different
initiatives we created with the investment
platforms in 2020 and 2021 in order to leverage
our engagement effort by empowering theinvestment professionals that already haveactive dialogues with issuers.

➜ Our progress in 2021

✔ We voted in over 7,300 annual general meetings (AGMs), representing a significant increase
compared to 2020 (4,240 AGMs).

✔ 547 engagements have been done on the energy transition and climate change, 165 on
natural capital preservation and 222 on social cohesion matters.

✔ We supported 86% of resolutions in favour of better integration of climate objectives. We
supported 83% of resolutions on social and human rights related topics.
✔ We also voted against executive compensation plans that did not have ESG indicators,
or climate-related KPIs which resulted in us opposing 45% of the relevant resolutions on this
topic.

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Principle 2
Signatories’ governance, resources and incentives support
stewardship.

1. How our structure supports and enables______
responsible investing and stewardship deployment
Because taking action as a responsible financial institution is an essential component ofAmundi's strategy, the governance structure now integrates issues of responsible management.
The responsibilities linked to achieving the group’s ESG objectives are reflected both in the
supervisory and management bodies, and in the way these governance bodies operate.
The responsible investment strategy is discussed at the highest levels. It is governed by dedicatedcommittees reporting to the Board of Directors and the General Management Committee. These
governance bodies interact with each other and with the various business lines working on theseissues, primarily via the Responsible Investment team.

Graph 2: Governance of ESG issues within Amundi

12 Strategic and CSR
Committee

3 Risk Management

Board of Directors

4 Compensation Committee

Committee

5 Appointments Committee

6 Audit Committee

7 Chief Executive Officer (CEO)8 Head of Institutional & Corporate Clients and ESG
9 Chief Responsible Investment Officer (CRIO)

10 General Management
Committee

11 Executive Committee

12 ESG and Climate Strategy Committee
14 ESG Rating
Committee

17 Investment Committee

Dedicated ESG
Department

13 Voting

15 ESG Management Committee

Committee

16 Risk Committee

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➜ Our progress in 2021
Responsible investment department as a standalone department6
In mid 2020, Amundi decided to adjust theorganisation around the Responsible Investment
department. Previously belonging to theInvestment Platform division under the supervisionof the Chief Investment Officer, the Responsible
Investment department has been positioned inJune 2020 as a standalone department, reporting
directly to Amundi CEO. This organisationalchange first reflected the recognition that the
Responsible Investment department should
serve both Amundi Investment professionals andAmundi clients segment needs, and secondly thatthe transformation at play could trigger strategic
decisions that should be taken at the highest
level of seniority. 2021 was the first complete year
during which Amundi has operated according tosuch new set-up, under the ultimate supervisionof our CEO, Valérie Baudson, in charge since May
2021.

2. A dedicated internal organisation to monitor andmanage the responsible investment strategy
As far as Responsible Investment is concerned, fourcommittees ensure the regular and structured followup of all work carried out. Amongst them, the ESG &Climate Strategy Committee is responsible for setting
and monitoring Responsible Investment strategy and ischaired by Amundi's CEO.

6. For further details on the Responsible Investment department’s increase of resources, see the tables "Key figures in2021" and "Our progress in 2021" page 15

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The ESG Strategic Committee
Chaired by Amundi’s CEO, this committee approves and monitors:– Amundi’s ESG and climate strategy– Strategic positioning of the Responsible Investment policy– Steering and monitoring the "Ambition 2025" plan
– Decisions on issues escalated from the ESG Ratings committee or the Voting committee

ESG Rating Committee

Voting Committee

Including senior managers frominvestment, financial, extra financia andrisk departments. Includes research, ESG,
compliance and risk departments.

Including ESG departments and external
advisors.

Responsible for:– Defining Amundi’s ESG methodologies,
systems, processes and resources– Approving the rules on exclusion andsectoral policies– Reviewing and taking decisions regarding
ESG rating on specific cases of exclusion
based of due diligences done by the ESG
team, or in case of escalation– Approving changes to the ESG
methodology requested by investment
managers– Developing Amundi’s ESG jurisprudence
on emerging issues
The Committee also deals with ESG topics
related to climate and the energy transition(such as our coal policy, carbon footprint
methodology, rating of issuers facing climate
related controversies), and social and societal
issues.

Responsible for:– Supervising the voting policy and its
consistency, acts as an adviser for voting
decisions on individual cases– Reviewing and validating the following
key voting activities:– Principles of Amundi as an active andresponsible shareholder, and interaction
with issuers– Periodic reports on voting activities– Local or individual issues not covered byvoting policies– Escalation process with issuers presenting
specific risks– Voting decisions for individual cases
where the implementation of the voting
policy could not be in the best interest of
the holders of the funds– Ensuring alignment of voting activities
with key ESG engagement themes

ESG Management Committee
Includes the senior leadership of the ESG department. This committee is responsible for:– Setting objectives and priorities for the ESG and voting teams– Building a consolidated view of ESG capabilities and resources across the Group– Promoting ESG across the business, addressing key client requests and business
opportunities

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➜ Our progress in 2021
Increased frequency of the ESG & Climate Strategic Committee
Early 2021, the periodicity of the ESG & Climate Strategic Committee has been increased froma quarterly to a monthly one. This decision was based in recognising that strategic decisions
and frequent monitoring should be performed at the highest level of the organisation,
considering the combination of following components: the strategic features of ESG & Climate
considerations, the systematic integration of ESG into the bulk of Amundi activities, the strong
client demand around ESG integration, the significant numbers of regulations that will comeinto force in coming years impacting activities, the required level of ESG scrutiny to maintainclients’ trust, as well as the sustainability challenges ahead of us, like Climate change.

3. A dedicated Responsible Investment team _____
Amundi has set up a team dedicated toresponsible investment, under the supervisionof Jean-Jacques Barbéris, an Executive
Director of the firm and Supervisor of ESG. This

department is positioned as an autonomous andindependent unit within the overall organisation,
serving the needs of institutional, distributor andretails clients as well as investment platforms.

a. General organisation and figures
The team is organized around four areas ofexpertise, each with its own senior leadership:– The ESG Research, Engagement and Voting
team– The ESG Method and Solutions team– The ESG Business Development & Advocacy
team,– The ESG COO OfficeStewardship Report 2021

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Graph 3: Organisation and positioning of the Responsible Investment team
Valérie Baudson
Amundi CEO

Jean-Jacques Barberis
Executive Committee Member andHead of Institutional Clients Coverage& ESG

Élodie Laugel
Chief Responsible Investment Officer

Hélène Nanty
COO OfficeTegwen Le Berthe

Caroline Le Meaux

Timothée Jaulin

ESG Method and SolutionsTeam

ESG Research, Engagement& Voting Team

Development and Advocacy
Team

ESG scoring methodology, engineering &ESG database monitoring

ESG Research /Caroline Le Meaux– Proprietary ESG analysis methodology– ESG Engagement policy– ESG Exclusion policy

ESG advisory, bespoke ESG solutions
development, advocacy & external
communication

Voting & Corporate Governance /Édouard Dubois– Assess resolutions and Vote at AGMs
– Pre-AGM discussions with companies

Source: Amundi, as of December 31, 2021

The Responsible Investment team has an overall average experience in the ESG / CSR industry of
6 years (the average experience in this area is comprised between 4 and 7 years depending on the
sub-department), and is composed of 64% women.

Graph. 4: Experience in the ESG / Corporate Social Responsibility industry of
Responsible Investment Team

19
14
11
In years

16

13

7

ESG Researchanalysts

5

4

4

Voting & Corporate
Governance analysts

ESG
Development &Advocacy

ESG Method& Solutions

Max experience (in years)

Average experience (in years)

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b. The ESG Research, Engagement and Voting team, the keystone ofstewardship exercise
Led by Caroline Le Meaux, the ESG Research,
Engagement and Voting team sits within the
Responsible Investment division at Amundi
and is an independent business line fromthe investment management and financial
analysis teams. This ensures the quality and the
independence of the ESG analysis, while allowing
to working in close collaboration with portfolio
management teams. Through its stewardship
activities, Amundi is seeking to have an impact
on the economy, as we truly believe that thisactive ownership can generally trigger stronger
outcomes that divestment in general.
Organised into two divisions, the Responsible
Investment team consists, at the end of 2021,
of 22 dedicated specialists7: 16 dedicated ESG
analysts and 6 Voting & Corporate Governancespecialists, spread across Paris, London, Munich,Dublin, Singapore, Tokyo, Hong Kong and theUnited States, that contribute actively to thestewardship effort.
– The ESG Research team is responsible forinternal ESG content and organises theengagement effort. Each analyst specializes
in various sectors and themes and is theprimary person responsible for driving
ESG research and engagement strategies
internally on those sectors and topics. ESG
analysts meet, engage and maintain constantdialogue with companies to improve their
ESG practices and have the final say over ESG
ratings of companies to ensure that internal
ESG scores are accurate and in line with key
Amundi convictions.
The team is also responsible for monitoring
sector trends, staying abreast of establishedand emerging ESG topics, assessing theimpact of ESG topics on the macro-sectors
covered (both risks and opportunities)
and the impact of those sectors on thesustainability factors.

While ESG analysts work in close
collaboration with research analysts andportfolio management teams of the broader
firm, their independent status ensures
the quality and the objectivity of the ESG
analysis that they carry out.
– The Amundi Voting & Corporate Governanceteam consists of specialists that analyse
resolutions and organise ongoing dialoguethat Amundi wishes to have with companies
pre and post Annual General Meeting(AGM) with the aim of better understanding
their strategy better and pushing forcontinuous improvement in practices. These
conversations are also an opportunity to
exchange with issuers on practices that
foster progress. We recognize that company
approaches take time to evolve and we look
for progress and momentum as much as
achievement. Our pre-AGM dialogue withcompanies aims to encourage ongoing
improvement backed concretely through ourvoting actions. By applying the general voting
policy principles, Amundi is able to cast votes
consistent with the shareholder dialogue.
This team is in charge of coordinating all votingrelated tasks, and responsible for managing thevoting rights that have been delegated by thefunds and subsidiaries.
The ESG Research, Engagement & Voting teamis the in-house center of ESG content expertisethat supports all of Amundi’s investment
platforms. The team members work actively
with fund managers and financial analysts tostrengthen ESG knowhow and expertise acrossthe whole company including ESG trends or
ESG positioning of issuers.

7. 31 people as of October 31st (23 dedicated ESG analysts and 8 voting & corporate governance specialists)

18

Stewardship Report 2021

The profiles of the ESG analysts are diverse andwe continue to seek to maintain a balance ofskills and backgrounds within the team. They areof seven nationalities and based in five offices
around the world, having had work experiencein 10 different countries. We believe this diversity
is one of the key features that contributes tothe quality of our ESG research. There is strong
experience across the team in analysis, bothon the sell- and buy-sides, but also a rangeof experience in audit and in ESG and CSR

October 2022

consultancy, as well as direct industry experiencein a variety of businesses, from fashion to
insurance, and from construction to IT software.
The team’s industry specialities are shaped bythis range of experience, and gives strong insight
into the operational challenges of business,enabling more thoughtful understanding of
the issues faced by the companies in which weinvest on clients’ behalf.

c. The ESG Research, Engagement and Voting team is supported bythree other teams– The ESG Method and Solutions team– The ESG COO Office

The team is led by Tegwen Le Berthe and is incharge of maintaining and developing Amundi’s
proprietary ESG scoring system and ESG-related
data management systems (including selecting
external data providers to generate proprietary
ESG scores, and making sustainability-related
data and analytics available). They help
analysts and portfolio managers integrate
ESG and sustainability considerations into
their investment decisions, as well as businessdevelopment teams to create innovative
solutions by integrating sustainability related
data within financial products (ESG ratings,
climate data, impact metrics, controversies…).
They oversee the development and integrationof analytical ESG tools in Amundi Portfolio
Management Systems and Client Reporting
Systems and are also in charge of implementing
clients’ specific ESG exclusion rules.

Under the responsibility of Hélène Nanty,
the team is in charge of coordinating andstreamlining
developments
betweenthe
Responsible Investment Business Line withthe 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.

– The ESG Business Development & Advocacy
team
Present in Paris, Munich, Tokyo and Hong
Kong, the team is in charge of supporting anddeveloping the ESG offering and solutions thatmatch investors’ needs and challenges, ESG
advisory and services for all Amundi clients, andmanaging ESG advocacy and collaboration withresponsible finance initiatives, and developing
training programs for our clients. The team is led
by Timothee Jaulin.

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Stewardship Report 2021

October 2022

KEY FIGURES IN 2021
As of December 31st, 2021, the Responsible Investment department had 40 members:✔ 5 people, within the ESG Method and Solutions team, are responsible for data provider
selection & ESG rating methodology✔ 16 people, within the ESG Research team, are responsible for ESG research & engagement(based in Paris, London, Dublin, Tokyo, Singapore)✔ 6 people, within the Amundi Voting & Corporate Governance team, are responsible forvoting pre-meeting dialogue✔ 10 people, within the ESG Business Development & Advocacy team, cover advocacy andthe development of new products and approaches through close dialogue with clients about
their needs (Paris, Munich, Hong Kong, Tokyo)✔ 3 people, within the ESG COO Office, offer central leadership and oversight➜ Our progress in 2021
Illustration 5: Reinforcement plan
In 2021, the Responsible Investment department increased from 33 members to 40, notably
through investment into the ESG Research team and the ESG Business Development team forwhich local resources outside the headquarters have been appointed in order to be closer toclients’ needs, and country’s local dynamic.
In September 2021, Amundi decided to further expand the department, with a reinforcement
plan of 16 collaborators spread across the diverse teams, amongst which 6 additional members
for the ESG Research team, 1 for the Voting & Corporate Governance team, 3 for the ESG
Method and Solutions and 4 on the ESG Business development & Advocacy team.

20 Stewardship Report 2021

October 2022

4. External research providers, an essential resourcea. Integrating external data in ESG analysis and rating work
Our ESG Research team leverages off data
provided by external providers. The information
received covers ESG scores, ESG controversies,
and other ESG-related information. Our
ESG analysis draws on this data to generate
proprietary scores and ratings, controversies
analysis, and processes the data to serve clients’specific exclusion requirements. Some external
research providers have also been chosen for
their climate-related data concerning climate
risk management and CO2 data.

operational efficiency and regulation), and theweights assigned to each criterion translate its
importance into the final ESG ratings. Our ESG
analysts retain discretion and are expected tomake an independent professional judgement
before agreeing on the Amundi ESG ratings. We
update our ratings on a monthly basis.

We source inputs from specialist global providers.
Each firm has its own methodology and inbuilt
biases. By taking inputs from a range of sources
and applying our own proprietary analysis andapproach, we can gain a fuller understanding ofcompanies and provide our investment teams
with unique and valuable insights.

– As data providers take different approaches
to analyse a particular criterion, the use ofmultiple data providers’ information gives
the ESG analysis team a 360° view on critical
ESG topics and relevant issuer behaviour.

We use these data sources to inform
our proprietary ESG analysis and rating
methodology. As far as Amundi ESG ratings
are concerned, this applies 38 quantifiable andmeasurable criteria reflecting key challenges bysector. Among them, 17 are applied across all
sectors and 21 are specific criteria only applied
to one or more sectors. These criteria areweighted using performance drivers (reputation,– It allows for a greater overall coverage ofissuers by combining different footprints(some providers have better coverage ofparticular regions/ sectors/asset classes).

– It gives Amundi access to more frequent
analysis updates, as each data provider
updates their analyses according to different
schedules.
– It enables Amundi selecting external
data methodologies wisely and to ensure
consistency with stated Amundi principles.
At present, the different data providers we use
are as follows

External data providers
General scope

ClimateControversies / controversial weapons
Sovereigns

21

Stewardship Report 2021

Such data providers are selected according toa dedicated due-diligence process performedby the ESG Method & Solution team, notably
in charge of maintaining and developing
Amundi’s proprietary ESG scoring system andOctober 2022

ESG-related data management systems. The
latter dimension covers selecting external data
providers to generate proprietary ESG scores,
and making sustainability-related data andanalytics available.

Illustration 6: Getting equipped with issuers’ temperature data, while methodologies
are still nascent
Since 2020, Amundi has been working on implementing temperature metrics to measurealignment of portfolios with global climate scenarios. After conducting data and methodology
review processes over 2020 and 2021, Amundi decided to use three providers, as methodolohgies
were from different, but strong underlying assumptions, and issuer coverage.

Notably :• All three providers, Trucost, Iceberg Data Lab8 and CDP analyse issuers’ ambitions. However,2 include past emissions in their trajectory estimates.
• Iceberg Data Lab proactively considers the credibility of issuers, analysing the actions
implemented in relation to issuers' commitments.
• Many issuers have yet to publish a carbon reduction target. As a result, one data provider has
chosen to apply a default +3.2°C degree trajectory for these issuers.
• Trucost has developed a different methodology for aggregating temperatures at the portfolio
level. Instead of using a weighted average, Trucost weighs the carbon budgets of each company
against a reference scenario in order to aggregate them at a portfolio level.
Data

Scope

Type

Specificities

CDP• Carbon reduction targets from the CDPquestionnaire

Scopes1+2+3

Absolute
and intensity• Carbon reduction targets only
• Baseline temperature (3.2°C)

Iceberg
Data Lab• Background: GHG emissions since 2010

Scopes
1+2+3

Intensity
only• Assessment of the credibility ofissuers

Trucost• Outlook: CDP and SBTi carbon reduction
targets• Background: Own GHG emissions since2010• Outlook: CDP & SBTi target + estimatedproduction projections• Sector approach for several
non SDA sector
Scopes
1+2

Intensity
only• S&P Physical output data used
to estimate trajectories

Amundi has chosen then to incorporate these different methodological approaches in order toperform the best possible assessment of portfolio temperatures.
Temperature modelling is not fully developed and needs to be monitored carefully. While
starting to implement this metrics, we engage in parallel with the data providers in order toprogressively promote a convergance toward a common approach.

8. Any trademarks or logos shown in this document are presented for illustrative purposes only and remain the propertyof their respective owners.

22

Stewardship Report 2021

Our ESG analysts also have access to informationfrom additional sources beyond these extrafinancial data providers, including:– Dialogue with companies’ management andstakeholders– Companies’ publicly disclosed documents– Equity and credit analysts of the AmundiGroup– Sectoral experts– NGOs, scientists, unions, media, brokers sellside reports– Bloomberg, Reuters
There is therefore a direct feedback loop fromengagement activity into the ESG ratings

October 2022

and analysis – and so into the integration of
ESG matters into the investment decisionsof our portfolio managers. These sources of
information form an essential component in the
ESG analysis process. They allow ESG analysts
to crosscheck information and data on specifictopics, as quality and reliability of information isessential.
All the information provided by external suppliers,
once quality checked and filtered through theprofessional assessment by our analysts, feeds
into our internal portfolio management system(ALTO). This insight in ALTO enables all of our
Portfolio Managers to deliver thoughtful andactive ESG fund management.

➜ Our progress in 2021
Illustration 7: Further reinforcing robustness of the ESG data processing and ratingproduction process
In 2021, in order to benefit from the robust processes already in place for the integrationof financial data, it has been decided to transfer the responsibility of the integration of the
ESG data and the monthly calculation of the ESG score from the Responsible Investment
department to the Global Data Management department. Specialized in data processing, 6
analysts will be specialized on ESG data integration and ESG rating production. Started in 2021,
this project is aimed to be completed in mid 2022.

b. The role of external providers to support our voting activity
Amundi’s Voting & Corporate Governance teamalso relies on services from external providers.
In particular, Amundi uses a platform, provided
by ISS – ProxyExchange - to monitor its voting
positions and to send its voting instructions.
Analysis from ISS, Glass Lewis, and Proxinvest
is available to more efficiently identify
problematic resolutions more efficiently, while
retaining complete autonomy from theirrecommendations.

ISS
also
providescustomized
votingrecommendations based on Amundi’s voting
policy. Using research and recommendations
from multiple proxy advisors allows the Voting&Corporate Governance team to make informed
voting decisions, taking into account different
viewpoints. The voting decisions are also
informed by the dialogue the Voting & Corporate
Governance team undertakes with companies
as well as the views of internal experts, including
the Responsible Investment team.

23

Stewardship Report 2021

All the votes are instructed on the voting
platform ProxyExchange in accordance with
Amundi's voting policy and with certain custom

October 2022

voting policies, provided for specific client
mandates.

c. ESG analysis at the core of our investment platforms
Amundi’s ESG analysis is embedded into
our portfolio management systems, madeavailable in real time in the fund managers’
tools to provide them with a seamless accessto corporate and sovereign issuers’ ESG ratings
alongside financial ratings.
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 fundmanagers to factor in sustainability risks in theirinvestment decision process and apply Amundi’s
exclusion policy whenever applicable. They arealso able to design and manage their portfolio
in compliance with specific ESG rules and ESG
objectives that may apply to the investment
strategies and products that fall under theirremit.

5. Integrating ESG considerations within remuneration
structures
ESG is integrated into remuneration structures
across the organisation, from the CEO
downwards.
The
Compensation
Committee
submits
the remuneration policy to the Board. The
compensation policy is aligned with theCompany’s corporate interest, its values, its
economic and commercial strategy and its
longterm objectives.

Through its role in defining all componentsof remuneration and benefits for executives,
the Compensation Committee’s work involves
ESG and climate issues in order to incorporate
them in structuring remuneration. Article 4 of
the Internal Regulations of Amundi's Boardof Directors specifies that the Compensation
Committee “analyses the remuneration policy
and its implementation with regard to social andenvironmental issues.”➜ Our progress in 2021
Illustration 8: Recommendation around integration of ESG and Climate issues
Over the course of 2021, the Remuneration Committee issued a recommendation on including
the integration of ESG and climate issues after reviewing the 2021 remuneration policy andanalysing the implementation of the 2020 remuneration policy. It also issued a recommendation
regarding the orientation of Amundi's gender equality policy, in light of its examination of thereport on gender equality in the workplace.

24 Stewardship Report 2021

ESG and climate issues are taken into accountin the Group's remuneration policies at several
levels and in multiple phases.
Reflecting the strategic importance of theseissues, a portion of the variable remuneration
attributed to Amundi's CEO is tied toenvironmental, social and governance indicators.
In 2021, ESG and CSR criteria weighted for
20% of the variable compensation granted
for performance year 2021, split across theimplementation of the ESG policy weights, thegender diversity of management bodies and theachievement of the Human and Societal projectof Credit Agricole SA.
Portfolio managers fully integrate ESG criteria
into their work. As such, targets related tothese criteria have a bearing on their annual
evaluations and discretionary bonus. Since 2021,
compliance with the Responsible Investment

October 2022

Policy has been included among qualitative
criteria for assessing the risk-adjusted aspects of
responsible investment. The 2018-2021 ESG plancalled for 100% of actively managed funds tointegrate ESG criteria, with the aim of achieving
an ESG rating higher than that of the respective
benchmark universe.
The salaries of ESG team members arebenchmarked against peers. Their variable
remuneration is based on both qualitative andquantitative analysis of their effectiveness anddelivery against expectations, as well as anelement of broader profit sharing based on
Amundi’s overall performance. All ESG teammembers are evaluated on their collaboration
with the investment teams and Clients’ segment
departments as well as according to the efforts
made to integrate ESG in the investment
processes.

➜ Our progress in 2021
Illustration 9: The announcement of a new "incentive plan"
As implementation of the “Ambition 2025” plan will only be possible with a well functionning
employee alignment system, Amundi has announced end of December 2021, the following new
incentives plan in December 2021..
– From 2022 onwards, in accordance with the commitment number 8 of the "Ambition 2025"
plan,– Amundi will gradually integrate ESG objectives in the performance assessment of
portfolio managers and sales representatives, so that the determination of their variable
compensation takes into account this dimension.
– The implementation of the “Ambition 2025” plan will account for 20% of the criteria
supporting the performance share plan granted to Amundi's 200 most senior managers.
– For the CEO, the ESG / CSR will weight for 20% of the annual variable remuneration
granted for performance year 2022. This 20% is split between 10% related to theimplementation of Amundi ESG projects and the other 10% are represented by the roll outof the Crédit Agricole S.A. Group’s Customer, Human and Societal Project. In addition, theimplementation of “Ambition 2025” plan will weight for 20% of the performance criteria
taken into account for the performance shares plan granted to the CEO.

25 Stewardship Report 2021

October 2022

Principle 3
Signatories manage conflicts of interest to put the bestinterests of clients and beneficiaries firstAmundi takes conflicts of interests very seriously and intends to minimize their occurrence. For
this reason, the firm has put in place numerous arrangements to drive transparency and ensurethat potential and actual conflict situations are monitored and dealt with.

Illustration 10: General measures to minimize and monitor conflicts of interests

Conflicts
register of crossdirectorships ofsenior Amundi
staff

Policy for managing
conflicts of interest
detailing employees’
responsibilities to
identify, prevent andmanage conflicts

Internal committees (broker/
dealer, products, risk
management, compliance,
audit, compensation), whichtake full account of ethicalconsiderations in their decisions

Procedures andrules governing
the primacyof the clientinterest

A DebtRestructuring
Committee

Procedures andrules governing
the selection andremuneration ofintermediaries

Appropriate training of
relevant employees to ensurethat they are fully aware of
their responsibilities andobligations

1. Amundi’s relationship with Crédit Agricole___From an ESG perspective, Amundi is participatingin elaborating Group policies of Crédit Agricole,setting common minimum exclusion principles
on certain sectors across the group’s activities(like for instance thermal coal). Minimum
standards are set such as ensuring Group andentities’ level of stated ambitions, considering
to group’s activities to serve best interest of
the clients. The derived policies are validated
through Group governance to which Amundi isrepresented and Amundi dedicated governance,in particular the Amundi ESG & Climate Strategic
Committee for strategic decision and theAmundi Rating Committee. Once the policies
are validated, these will apply to all Amundi’s
active investing strategies over which Amundi
has full discretion and ESG ETF products range.
On top of these minimum requirements, Amundi
can apply additional exclusions, as appropriate.
Amundi’s exclusion policies are defined by the26 Stewardship Report 2021

Rating committee based on propositions madeby the ESG department. Provided minimum
standards Group requirement are complied
with, Amundi manages assets on behalf of its
clients, in their best interest through dedicatedOctober 2022

governance in all aspects of ESG, including
engagement and voting that are conducted infull independence.

2. Avoiding conflicts of interest in stewardship
activities
Conflicts of interests may arise when exercisingstewardship activities. Avoiding them is essential
to preserve the best interest of our clients andbeneficiaries. For this reason and in addition

to generic measures taken at Amundi’s level,
specific measures apply at the stewardship level.

a. A global setup intended to prevent conflicts of interests– Organisational measures - Amundi
maintains strict independence of the voting
and stewardship function from the client
relationships area to segregate stewardshipfrom any possible conflicts.
– Procedures and controls – The following
mechanisms are in place: ➊ internal policy
on conflicts and code of ethics, requiring
employees to identify, mitigate and manage
conflicts; ➋ strict procedures asserting
the primacy of clients’ best interests; and➌ an ad-hoc committee can be called todeal with the approach to any appropriate

conflict. For example, any voting decision in
relation to Amundi’s partner and joint venturecompanies is automatically escalated to the
Voting Committee and the decision-making
on all votes is fully documented – withparticular attention to any situation where thevote is not in accord with the usual Amundi
voting policy.
– A remuneration policy that aligns theinterests of our senior management andinvestment staff with those of our clients.

b. Voting on companies that have links with Amundi
In the exercise of the voting rights of its openended funds, Amundi may face situations ofpotential conflicts of interest. Measures toprevent and manage such risks have therefore
been put in place.
The first preventive measure is the definition andpublication of the voting policy validated by the
management bodies of the group’s managementcompanies.
The second measure consists of submitting tothe Voting Committee, for validation prior to
the general meeting, the voting proposals forresolutions relating to a pre-established list oflisted companies that are sensitive because of
their links with Amundi.

These sensitive listed companies for which a
potential “conflict of interest” has been preidentified, are defined as follows:
1. Issuers with a controlling interest in Amundi orowned by Amundi,
2. Issuers which are our Partners,
3. Issuers with which Amundi shares an Executive
Officer/Director,
4. Issuers that are among the most significant
clients of Amundi.
In addition to these previously identified issuers,
the Voting & Corporate Governance team also
submits to the voting committee any potential
conflicts of interest that may result from theanalysis of resolutions from general meetings.

27

Stewardship Report 2021

October 2022

Case study 1: Management of conflict of interests
During 2021, the voting committee was asked to confirm a proposed voting decision on behalfof Amundi’s clients at a finance company that is a distributor of Amundi’s products. We wereconcerned by the resolution regarding executive remuneration. In particular, the stringency of
the remuneration criteria seemed difficult to assess, and the CSR and climate-related KPIs werevague and undemanding.
We concluded that it was not appropriate to support the proposed remuneration on behalfof clients without greater clarity regarding the link of pay to performance. We challenged theboard’s delegation and control of risk from the top to lower levels in the organization.
The board did neither recognize a pattern nor take sufficient responsibility over the past
years. We choose to escalate by voting against the renewal of 2 board members, members of
the remuneration committee. The voting committee confirmed this decision to vote against,
notwithstanding the existence of the conflict of interest.

3. Other specific initiatives to avoid conflicts of interest
When a need is identified, Amundi takes steps to minimise and monitor potential and actual conflicts.

➜ Our progress in 2021
Examples of specific measures are described below.

At employees’ level
In 2021, Amundi decided to reinforce its management of conflict of interests and detailed
policy is being finalised. It will be made publicly available during Q2 2022. It includes prevention
measures and covers the management of conflicts for all Amundi employees. It incorporates
a risk mapping of potential conflicts and details the prevention and control measures as well
as applicable procedures. It also includes a process for dealing with conflicts of interests, anda description of the control framework. All employees are required to complete a conflicts ofinterest declaration and attestation on an annual basis.
A new training programme on conflicts of interest will be rolled out for all the entities ofAmundi Group in H2 2022. The conflicts of interest prevention and management framework isscheduled to be regularly reassessed by the compliance department with the participation of
all business lines involved. We will continue to enhance our approach with regards to conflicts
in the area of ESG and stewardship specifically, to ensure that clients have full confidence that
we continue to operate solely in their best interests.

28 Stewardship Report 2021

October 2022

When restructuring debt and/or capitalIn the context of a restructuring of a debt or of the capital of an issuer, Amundi has set up a
specific process, in 2021, to closely manage the risks and the potential conflicts of interests.
These may arise from Amundi being simultaneously invested in different parts of the capital
structure or in equities and debt where the respective interests of each investment in theoutcome of the restructuring are asymmetrical. The Active Distressed Securities Committee ofAmundi (UK) Ltd has authority to monitor specific restructuring situations, review the positions
across all the portfolios under its responsibility and take the decisions needed to manage therestructuring in the best interests of each type of holding and/or portfolio. This committee isinformed by analysis conducted by the distressed debt investment team on each distressed
exposure (bonds, equities, options, any specific securities). The committee is chaired by the
Global Head of the Emerging Markets business line and includes members of the emerging
investment teams, the risk, compliance and legal departments and representatives fromeach management Company which could be impacted by its decisions. Risk and compliance
representatives have a power of veto to ensure no unreasonable risks are taken in the portfolios
and that potential conflicts of interests, if any, are managed properly. Finally, the final decision iswell balanced and takes the best interests of all clients into account. When the committee has
finalized a decision that includes voting, it shares it with the Voting & Corporate Governanceteam who will be in charge of the implementation of the voting decision.

29 Stewardship Report 2021

October 2022

Principle 4
Signatories identify and respond to market-wide andsystemic risks to promote a well-functioning financial
system.
The Group has a culture of prudence and develops a comprehensive framework to control therisks associated with its activities.
Amundi believes that a well-functioning financial system can only be achieved by the combinationof ➊ a rigorous risk management at entities level, with ➋ the dedication to promote goodpractices through risk-management related innovations and coalition.
Amundi understands that risk is multi-facetedand operates over different time-periods,
requiring to look beyond market risk, and take
into account credit, liquidity, and reputationalrisks, as well as ESG risk generated by acompany’s activities.

Investment professionals are supported byan independent risk department with a broad
scope, and an ESG team that accesses specialist
research and can provide its own in-depth
analysis of ESG risks likely to impact portfolios.

1. Rigorous risk management to frame our activities
a. Identification of market-wide risks
Asset management is first and foremost a risk
management activity, which is why Amundi
constantly ensures that its organisation andprocesses enable it to identify and control
risks. This approach is characterised by thesharing of experiences and good practices on
the understanding and management of risks,
facilitated by: operation in cross-functional
business lines, systematic representation of theRisk, Compliance and Security control functions
on the various investment management
committees (products, investments, ESG, etc.), asingle IT platform with risk assessment tools andmethods, creating a common reference system
for all teams, initiatives aimed at informing anddiscussing the various risks associated with thecompany’s activity. Maintaining a risk culture
also involves making clients aware of the risks
to which their assets are exposed. Amundi
publishes studies for its clients that describe
these risks and their economic evolution, as wellas the solutions to capitalise on them.
In the course of its business, Amundi is mainly
exposed to risks related to third-party asset
management activities and to financial risks,arising mainly from the management of its
investment portfolio and the guarantees granted
to certain products. The table below provides asummary.

30 Stewardship Report 2021

October 2022

Illustration 11: Summary of market-wide risks faced by Amundi
Investment risks

Other risks• Credit risks• Operational risks• Market risks– Mandate objectives• Liquidity risks– Process malfunction, human error;• ESG risk

– Non-compliance, tax and legal;– Business discontinuity (including cybersecurity);– Human Resources.
• Business risks• CSR risks (including duty of care, corruption)

b. A dedicated internal control system supported by adequate
resources
General Management clearly defines the roles
and responsibilities of internal control functions
and allocates the appropriate resources. Theinternal control system covers the entire Groupin France and internationally and is based on thefollowing fundamental principles: systematic
reporting to the Board of Directors on risk
management, monitoring of limits, controls andresults, and significant incidents, comprehensive
coverage of businesses and risks, a clear

definition of responsibilities, through formalised
and updated delegations, effective separationof investment and control functions.
The internal control system is based on two
main pillars:– risk measurement, monitoring and control
systems,– a control mechanism.

Stewardship Report 2021

October 2022

Illustration 12: Internal resources dedicated to risk and control management
Headcount of business lines as of 01/01/2022

255
Risk
Department

136

30

ComplianceDepartment

Security
Department

Amundi
Board
Committees

46
Internal
audit

Board Risk Committee and Audit Committee

Periodic
Control
Level 3

Internal Control Committee
Audit-Inspection
Group Risk Committee, Compliance Committee, Security Committee

Permanent
Control
Level 2

Permanent
Control
Level 1

Checks:Function
Risks

Investment
Operational
Proprietary

Checks:Function
Compliance

Financial security
Market integrity
EthicsClient protection
Fraud and corruption

Checks:Function
Security

IT security
Personal data
Business continuity
Safety and Securityof people and assets

Policies and procedures

31

Controls exercised by the operational units through the principle of separationof functions and hierarchical controlsc. Focus on integration of ESG risks into risk management processes
ESG criteria are integrated into Amundi's control
framework, and responsibilities are divided
between the first level of controls, conductedby the Investment teams, and the second levelof controls, carried out by the Risk teams. Theselatter may at any time verify the complianceof a fund with ESG objectives and constraints.
The Risk department is part of the governanceframework
designedaroundresponsible
investment. It monitors compliance withregulatory requirements and the managementof risks related to these issues. Responsible
investment rules are monitored by the Risk

teams in the same way as any other rule within
their sight, using the same tools and procedures.
These rules include exclusion policies, eligibility
criteria and fund-specific rules. Compliancechecks for these rules are automated in theform of an internal compliance tool with pretransactional or blocking alerts. These inform
fund managers of potential breaches, after
which they are required to restore portfolio
compliance. This applies most notably to
exclusion policies.

d. Physical and transition risk identification and assessment
Amundi has established indicators and targets
to identify, qualify and effectively manage
climate-related risks and opportunities. Using awide range of indicators, Amundi is able to set

short-, medium- and long-term targets. For thispurpose, Amundi relies on a broad set of data
providers to guarantee that its measurements
and assessments are as accurate as possible.

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Stewardship Report 2021

During 2020 and 2021, Amundi has been working
to diversify the indicators used to integrate
climate-related risks and opportunities. These
include portfolio temperature scores and Paris
Agreement alignment indicators, as well as
green- and brown-share indicators. As tools
for calculating transition risks that complement
issuers’ carbon footprint, the introduction ofthese new indicators gives Amundi a more
forward-looking and comprehensive view of its
climate investment portfolio’s performance.

Process for identifying physical climate
risks
While Amundi has identified both short- andlong-term physical risks that potentially havea significant impact on investment portfolios,
the information available for assessing financial
impact is limited and often lacks standardisation
across sectors and regions. Therefore, Amundi's
approach to physical climate risk assessment
is applied to dedicated climate strategies.
Investment portfolios are exposed to variably
acute and chronic climate risk depending
on companies’ sectors and geography, andincreased climate risk can have a significant
impact on the financial performance of sectors
with high climate risk.

October 2022

Process for identifying and managing
climate, market and transition risks
Amundi's takes a threefold approach:• Calculate carbon risk: the degree of exposure
to risk should be assessed before taking action
to reduce such risk;• Assess: scoring in terms of energy transition
to reflect a company’s exposure to energy
transition risk and how this risk is anticipatedand managed by management;• Anticipate: estimating the impact of nonconvergence risk (+2°C objective) on theperformance of a portfolio of securities.
Several tools are available to our investment
professionals to apply this approach in practice.

Amundi's approach to physical climate risk
assessment is based on data and methodology
developed by Trucost9. Trucost maps thelocation data for companies' physical assets
against seven climate hazards (fire, cold wave,
heatwave, sea level rise, flood, tornado anddrought) to analyse issuers’ sensitivity to thesedifferent risks.

9. Any trademarks or logos shown in this document are presented for illustrative purposes only and remain the propertyof their respective owners.

33 Stewardship Report 2021

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2. Promoting good practices through riskmanagement related innovation and coalition
We believe that investing for the long term is
an advantage. This makes the integration of
ESG into our investment approach a naturalexpression of this belief.. Our view that value
creation goes beyond performance requires us
to consider major systemic sustainability risks,such as climate change and growing inequalities.
We recognise our responsibility to contributeto efforts to address systemic issues, as well as
to efficiently allocate capital for the future. Ourrole in raising standards, not least in terms of
ESG performance by the companies in which
we invest, is a key part of this responsibility. In
general, we recognise that the private sector
must integrate environmental, societal andgovernance issues for four main reasons:
1. In a more liberal economy, economic andfinancial actors have a greater responsibility
towards society.
2. As long-term investors, asset managers havea major role to play in directing capital towards,
for example, projects related to the energy
transition.
3. We must also influence the strategies ofcompanies, especially when we are among theirmain shareholders. ESG is a means of channellingmoney to the leading actors on these criteria, oron the contrary to put pressure on laggards, aspart of a constructive dialogue.
4. We have a responsibility to our clients: wemust deliver performance over the long-term.
In a world where intangible assets represent
an important part of the overall valuation ofcompanies, ESG makes it possible to capture
the decisive criteria over the long-term.
As far as Sustainability risk is concerned, Amundi
does consider its contribution to the required
collective effort, through– the development of investment solutions
enabling to direct capital where the financing
needs are,– an active, constructive and demanding
shareholder dialogue (see Principle 9 formore details on these actions)– the promotion of good practices in risks
areas by contributing to collective initiatives(see Principle 10 for more details on theseactions).

Illustration 13: Commitment on three specific frontiers to promote a well-functioning
financial sector
With regard to Climate risk, mobilising the private financial sector at scale remains a significant
challenge in financing climate policy and sustainable development, particularly in Emerging
Markets and Developing Economies. Blended finance can be a solution to leverage on public
capital to de-risk private investments and channel massive private investments across amultitude of works: developing key financial system infrastructures, support undeveloped
segments of a market, while offering international investors investment opportunities withthe right risk/return via mechanisms that include, but are not limited to, guarantees or credit
enhancements.
To build bridges between climate-related investment demand on one side and climate-related
financing needs on the other, Amundi has developed several private and public partnerships
aiming at igniting a well-functioning green bonds market. .

34 Stewardship Report 2021

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Case study 2: Geographic Frontier – Emerging markets
In partnership with the International Finance Corporation (IFC), Amundi has developed an
approach that seeks to address the costly gap between the low-yield environment in developed
markets that investors face and the extensive green infrastructure financing needs in developing
economies. Amundi was selected by the IFC as its partner for implementing an innovative
solution consisting of a fund, launched in March 2018 – the Amundi Planet Emerging Green
One (AP EGO or “the Fund”) – with additional support from the IFC’s Green Bond Technical
Assistance Program (“GB-TAP”, or “the Program”). The partnership provides an innovative
platform that combines extensive expertise in asset management (Amundi) with private sector
development in EM (IFC) to help developing economies achieve long-term sustainable growth.
In 2021, the partnership enabled to– Support enhanced data availability and share the IFC’s methodology for ESG risk analysis
through global public goods (IFC’s ESG Performance Indicators for Capital Markets, IFC’s
Environmental and Social Management System Diagnostic Tool for Financial Institutions)– Conduct training for EM financial institutions on green bond issuance to further stimulate
growth of EM green bond issuance (e.g. four cohorts of the Green, Social, and Sustainability(GSS) Bonds Executive Online Training, which included a total of 134 participants (43%women) from 47 financial institutions located in 22 different countries)– Increase awareness of the green bond principles and disseminate best practices in green
finance,– Increase the supply of EM green bonds. In turn this enabled us to allocation to green bonds
at a steady progression pace well above the 40% targeted allocation for Year 4.

EM green bond ramp-up progress
100

%

100

80

70
60

53.97
45.99

40

20

50

31.75
16.54

40
25
Percentage of green bonds
Investment guidelines (in %)15
0
End Y1End Y2End Y3

End Y4

End Y5End Y6

End Y7

Source: Amundi, fund data as of 31/12/21 on a mark-to-market basis.

Number of green bonds in portfolio:
Weight of green bonds in the portfolio:

34
53.97%In 2021, a new partnership in collaboration with the International Finance Corporation has beenset, announcing the launch of the “Build Back Better Emerging Markets Sustainable Transition”(BEST) strategy, a USD2 billion program to support a green, resilient and inclusive recovery
from the Covid pandemic in Emerging Markets.

35 Stewardship Report 2021

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Case study 3: Instrument Frontier - New and under-developed sectors
In September 2020, the Asian Infrastructure Investment Bank (AIIB) and Amundi launched the
AIIB-Amundi Climate Change Investment Framework (CCIF). Endorsed by the Climate Bonds
Initiative (CBI), the AIIB-Amundi Climate Change Investment Framework's approach translates
the key objectives of the Paris Agreement into fundamental metrics to assess an issuer’s levelof alignment with climate change mitigation, adaptation and low-carbon transition objectives.
The CCIF delivers an extra financial impact as it is designed to encourage the integration ofclimate change risks and opportunities into business practices by targeting the engagementof B-list issuers (future climate champions with effective engagement) to help them transition
to A-list credentials (climate champions).
This new investor tool provides, for the first time, a holistic issuer-level assessment of bothclimate change risks and opportunities. This framework, made public to promote common
market practices, was utilised to launch in January 2021, the Asia Climate Bond Portfolio, a
US USD300 million fixed income portfolio, actively managed by Amundi teams, which seeks
outperformance by identifying, analysing and selecting tomorrow’s Climate Champions. In 2021,
almost half of the portfolio was comprised of bonds issued with the aim of financing infrastructure
programs in sectors such as power and renewable electricity production, telecommunication
services, transportation, gas utilities, and road & rail. A fourth of the allocation was dedicatedto financing projects from other productive sectors, such as automobiles, chemicals, paper &forest products, and semiconductor equipment.

Case study 4: Issuer Frontier - Private debt markets
Launched in 2019 by Amundi with the support of the European Investment Bank, the objectiveof the Green Credit Continuum (GRECO) program is to support the most impactful, yet
underdeveloped segments of green debt markets in Europe: high yield issuances, securitizations
and private debt.
2021 was a very dynamic year for the green bonds market, especially in the high yield segment,
enabling Amundi to complete 10 new transactions and perform our first capital.
With respect to private debt market and securitization, which are still at an early stage of
growth and we continued our efforts to increase the supply. GRECO carried out its second
transaction in the securitized segment in H1 2021 through a Dutch mortgage provider. We
valued the provider strategy and the discounted rate offered by the bank to promote green
projects among its clients, which also providers a strong rationale for regularly issuing green
bonds. The provider has developed a list of proposed Nominated Projects & Assets which
comply with the Low Carbon Buildings sector criteria of the Climate Bonds Standard.

Such initiatives have been complemented by additional commitments in 2021 and contribution tomarket standards and coalitions, in order to promote a well-functioning financial system, especiallyconcerning Sustainability risks.

36 Stewardship Report 2021

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Illustration 14: Commitment to the Net Zero Asset Manager initiative
On July 6th 2021, Amundi joined the Net Zero AssetManagers initiative10 and announced its intention
to gradually align its portfolios and operations witha net zero emissions target by 2050 to limit global
warming to 1.5°C. The Net Zero Asset Managers
initiative is a group of 273 global asset managers
with $61.3 trillion in assets under management11
who have pledged to support the goal of zeronet greenhouse gas emissions by 2050 or sooner,
consistent with global efforts to limit warming to
1.5°C, and to support investment aligned with thisgoal.
This announcement constitutes a key step inAmundi's strategy to fight climate change andreflects the Group's convictions in this area,
namely that:• The financial sector is a key catalyst for action;• Amundi must undertake to fight climate change at every level of the company;• The transition will have to be fair, respectful of the environment, and aim to preserve andrestore the latter;• Knowledge, data and analysis are major drivers of change.
Amundi's “Ambition 2025” plan provides a concrete roadmap for meeting the Group’s statedcommitment to help achieve carbon neutrality.

Illustration 15: Amundi's active participation in Green Bond Principles Executive
Committee
The Green Bond Principle have been developed and published as voluntary guidance to bondmarket participants for the issuance of Green Bonds. Amundi has been re-elected as a memberof the Green Bond Principles Executive Committee for the year 2021-2022.
Amundi was involved in several working group (Impact Reporting, Climate Transition Finance,
Sustainability-Linked Bonds, Social Bonds, Secured Sustainable Bonds task force).

10. This international initiative brings together asset managers who are committed to transitioning their investment
portfolio to carbon neutrality by 2050.
11. Figure as of July 2021.

37

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Illustration 16: The example of biodiversity loss related risks

Biodiversity loss in turn poses significant risks for society at large and also the companies weinvest in. These include risks to food security, human health, and increased severity of physicalevents, which could have consequences not only for society but also for economic stability. The
World Economic Forum’s Global Risks Report12 has for the past five years identified biodiversity
loss and ecosystem collapse as a high level of global risk in terms of impact and likelihood. The
WEF also found in 202013 that half of world’s total GDP is moderately or highly dependent on
nature and its services and, as a result, exposed to risks from nature loss.
Corporates and corporate actions both depend on biodiversity but also impact biodiversity
loss. They derive value and material benefits from ecosystem services yet conversely, theiractivities put increasing pressure on the stability and reliability of the services and materials
that nature.
Amundi is an active member of the Finance for Biodiversity Pledge This initiative brings
together 84 financial institutions from around the globe, committing to protect and restore
biodiversity through their finance activities and investments.
Amundi represented the signatories with a speech at the High Level Segment of the Fifteenth
United Nations Conference on Biodiversity (COP15) to call on global leaders to protect andrestore biodiversity.
In 2021, Amundi launched a specific engagement campaign on biodiversity (more details in
Principle 9).

12. https://www3.weforum.org/docs/WEF_The_Global_Risks_Report_2021.pdf
13. http://www3.weforum.org/docs/WEF_New_Nature_Economy_Report_2020.pdf

38 Stewardship Report 2021

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Principle 5Signatories review their policies, assure their processes andassess the effectiveness of their activities.

1. Review and assurance of our ESG approach___Each of the four key ESG committees is
responsible for reviewing the policies andprocesses under their remit on an annual basis
at the minimum.
• ESG Strategic Committee• ESG Rating Committee• Voting Committee• ESG Management Committee(More details on the four ESG committees in
Principe 2)
They also oversee our progress towards
delivering the changes necessary to fulfil our“Ambition 2025” plan’s objectives (see Principle1), having successfully achieved those for the
2018-2021 ESG plan.
On specific funds, we have French Socially
Responsible Investment (SRI) labels inplace and apply the International Financial
Corporation’s (IFC) Performance Standards. A
significant part of Amundi’s funds are certified
by other French or international labels14, and are
therefore audited to ensure that the associatedrequirements are verified. We reinforce theseexternal certifications through our internal
assurance and oversight processes.

2. A three level control process on ESG topics___
Amundi operates a 3-level control to ensure the consistency and good implementation of our
Responsible Investment approach:a. Risk Department.
ESG constraints are verified daily by our Risk
Department. This ensures compliance with
Amundi’s exclusion policy and ESG-specificportfolio guidelines. ESG ratings (see Principle
7 for more details on the methodology) areamong the tools available to the risk department.
This enables ESG topics to be integrated
within Amundi’s control framework. The risk

department oversees adherence to regulatory
requirements and management of risks related
to these topics, as well as monitoring adherence
to ESG constraints (whether exclusions or otherrules) within mandates – which are regardedin the same way as any other contractual
requirements. Alerts for potential breaches areautomated both pre and post-trade.

14. Essentially depending on the countries of distribution, the typology of clients, etc.

39 Stewardship Report 2021

October 2022

b. Internal Audit Department
Our ESG processes and systems are also
audited internally by Amundi’s Internal Audit
Department. This oversight plays a key role inour oversight of ESG processes and systems,
providing confidence and assurance about
quality and consistency of our approachand delivery. The Audit team is independentand provides challenge and input across thebusiness.

c. Group General Inspection (IGL)
Finally, the Group General Inspection (IGL)
punctually leads different types of missions
on ESG topics, to ensure the well-functioningof processes, the monitoring of risks, etc. The
Group Inspector General reports directly to theChief Executive Officer of Crédit Agricole S.A.
They report regularly to various bodies: Crédit
Agricole S.A.'s Audit and Risk Committee,
the Group Internal Control Committee andCrédit Agricole S.A.'s General Management
Committee. They also regularly interact with theregulators, primarily the Prudential Supervision
and Resolution Authority.

Here are some examples of the main activitiesof the Audit/Inspection units:– joint approval of audit plans, with IGL being
the final decision-maker,– communication to IGL of the conclusions ofaudit assignments,– regular activity reporting to IGL by the AuditInspection units.

Given the sensitivity on ESG topics and the material importance for Amundi to protect
its clients trust, Amundi may seek external assurance, over and above these three levelsof control.

3. Dedicated control of data_________________
Two levels of quality controls are applied on the
ESG data inputted into our systems: the first
relates to data (project management), and thesecond to business lines.
– The first, data-related quality control, is
performed on the files provided by suppliers.
It covers, in particular: ➊ checking the files’
contents, not least to ensure scores are upto-date; and ➋ checking the format quality of
the files provided by suppliers.

team to intervene. Every month, in order tocalculate ratings, a ratings simulation is sent
to the entire team. Each analyst then validates
the ratings of the companies that they oversee.
In each step in the process, multiple quality
controls are performed, including:– controls on stability of the analysis universe,
identifying entries and departures from theuniverse or those that are excluded, as well ascompanies coming close to doing so; and– The second-level controls in the business line
ensures the integration quality and scoringof the criteria. It is particularly used to detect
missing criteria, as well as insignificant or
anomalous scores.

– controls analysing the rotation rate, verifying
the dynamic of the rating breakdowns byquintile between different months, andperformed with respect to the overall rating(ESG) as well as each individual component(E, S, and G).

Relevant alerts require members of the analyst

40 Stewardship Report 2021

October 2022

➜ Our progress in 2021
Illustration 17: Risk team’s input into our Stewardship activity and ESG work
An annual risk assessment of our voting processes has been carried out for each of the last
four years. The number of AGMs at which we voted doubled over that time frame, and there
was an increase of more than 25% in the number of resolutions considered. The review process
noted only a small number of operational issues. Following such review, we implemented a setof recommendations from this review process to enhance our procedures and remove the riskof human error, across a range of areas including:– ensuring all portfolios are covered by our voting approach,– all appropriate holdings are voted,– powers of attorney are up to date, - stock recalls are successful,– and ensuring our record-keeping covers every vote against management.

Illustration 18: External assurance in the context of the Amundi 2021 ESG Ambition
plan achievement
Following the implementation of the 100%
ESG integration objective related to theAmundi 2018-2021 ESG plan, an independent
mission was conducted by PwC in April 2021
verify that it has been correctly implemented
in the eligible scope of funds.

Illustration 19: External assurance in the context of the Amundi responsible
Investment AUM publication
Regarding the annual publication and reporting of AUM qualified as Responsible Investments,
Amundi's statutory auditors have carried out procedures on the amount of assets undermanagement classified as Responsible Investments by Amundi of EUR847 billion as at 31
December 2021. Statutory auditors have issued a limited assurance report on the assets undermanagement reported as Responsible Investments by Amundi which is presented in the
Universal Registration Document for the financial year ended 2021. Their report indicates thatbased on the work they have performed and the evidence they have obtained, nothing hascome to their attention that causes them to believe that the information is not prepared, in allmaterial respects, in accordance with the Amundi reference framework.

41

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INVESTMENT APPROACH

Principle 6
Signatories take account of client and beneficiary needs
and communicate the activities and outcomes of theirstewardship and investment to them.
Amundi recognises the fiduciary duty placed on our shoulders by clients entrusting us with theirmoney, and we work to deliver on that duty by investing with their long-term interests at heart.
We believe that our active stewardship framework can deliver meaningful change and value
added over a 3-year horizon, on average. However, in some areas, it could take longer and weare prepared to stay the course. “Investing for the long term is an advantage” is one of our core
investment beliefs. All clients should benefit from our long-term investment approach and ouroverall Responsible Investment approach.

1. Tailoring our approach to client needs ssdfqfddc
Graph 5: AUM by geography and asset class (as of end of December 2021)
Where our clients’ assets are invested

Americas asset exposure (€b)
Equities

68

Fixed income

34

Europe asset exposure (€b)

Money market

3

Equities

189

Equities

74

Multi-asset

4

Fixed income

635

Fixed income

54

Other

2

Money market

176

Money market

32

Total

111

Multi-asset

143

Multi-asset

24

Other

82

Other

3

Total

1,225

Total

187

Asia asset exposure (€b)

Other emerging asset
exposure (€b)
Global developed markets
exposure (€b)(of whichare passive)

Global asset exposure (€b)

Equities

23

Fixed income

210Equities

72

Equities

426

113

Money market

Fixed income

84

Fixed income

828

18

Multi-asset

1

Money market

19

Money market

230

0

Other

0

Multi-asset

150

Multi-asset

322

2

Total

45

Other

23

Other

110

0

Total

348

Total

1,916

133

2. See Amundi’s responsible investment policy

42 Stewardship Report 2021

October 2022

a. Our overall Responsible Investment approach
Please note that the ESG rating scale is discussed
in more detail in the ESG Integration chapter ofthe report (Principle 7).
In all actively managed portfolios for which
Amundi has full discretion, as well as in our
ESG ETF products range, we apply a sectoral
exclusion policy, and bar investment in assets
from issuers that we deem of lowest ESG
quality (rated G on our A-G scale). For any new
mandate or dedicated fund, Amundi’s exclusion
policy shall be implemented in accordance with

our pre-contractual documentation,otherwise requested by a client.

unless

Our shareholder engagement approach applies
across all of our assets under management,
including passively managed funds. Our
Responsible Investment solutions encompass
the following approaches that can be exclusive
or combined: negative screening, best-in-classscreening, norms-based screening, sustainability
themed investing, Impact investing.

b. Our Responsible Investment assets under management
As of end December 2021, Amundi managed
EUR847 billion of Responsible Investment
assets in the following areas, aiming to address
the diverse ESG preferences of our clients:– Broad ESG integration solutions: Portfoliosthat take into account E, S, and G criteria
simultaneously in addition to traditional
financial analysis. These solutions meet thevast range of responsible investment needs,
objectives and motivations of our clients.

Most of these solutions, placed at the coreof our ESG offering, combine a best-inclass approach, which consists in selecting
within each sector the issuers with the best
ESG practices. Many individual products,
family of funds, etc. also have deeper ESG
integration, through higher selectivity, rating
or non-financial indicator upgrade, thematic
selection, etc.

➜ Our progress in 2021
During 2021, Amundi defined its new ambition related to Broad ESG integration solutions. As
stated by the “Ambition 2025” plan presented in December 2021, a new transition assessmentscore will be considered for the broad ESG integration solutions, to evaluate the companies on
their journey towards a low-carbon economy. We also plan to expand our ESG passive offering
to reach 40% of the total passively managed product range by 2025. This will be achieved
by developing new products and by proactively converting standard exposures into an ESG
equivalent.

– Sustainability themed investment
solutions: Thematic and impact-oriented
portfolios such as Paris-Aligned or Climate
Transition (PAB/ CTB) index solutions,
Just Transition for climate solutions, green,social and sustainability bond funds, green
infrastructure / debt and others. Some ofthese initiatives have been developed inpartnership with key public and private
actors, such as the International FinanceCorporation (IFC), the Asian Infrastructure
Investment Bank (AIIB), the European
Investment Bank (EIB), or Electricité deFrance (EDF).

43 Stewardship Report 2021

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➜ Our progress in 2021
As of end of December 2021, the Sustainability themed investment solutions, dedicated to
specific initiatives promoting environmental and energy transition or social cohesion15, reached
EUR34.8 billion.
During 2021, Amundi defined its new ambition related to Sustainability themed investment
solutions. As stated by the “Ambition 2025” plan presented in December 2021, Amundi iscommitted to support their deployment with the development of Net Zero 2050 funds over all
main asset classes, and an objective of asset under managements in impact funds of EUR20
billion.

c. Understanding and responding to client needs
Amundi seeks to build close relationships with clients, to understand their needs and to ensure that
products are tailored appropriately.

➜ Our progress in 2021
One of the objectives of our 2018-2021 ESG plan was to strengthen our strategic advisory
activities to support our clients in their ESG development initiatives. Depending on individual
client ESG integration goals and constraints, we developed in 2021 the following advisory
capabilities support:– Defining an ESG charter– Creating a database of ESG criteria and calculating ad hoc ESG ratings– A customised engagement program focusing on specific themes– ESG analytical and portfolio management tools via Amundi’s proprietary ALTO system.
– Designing an ESG reporting system– Customised training programs covering various aspects of ESG such as integration
methodologies, scoring systems, voting and the SDGs.
Feedback is formally collected from clients in order for us to continually improve the quality of
the advisory and training services that we provide.

15. The objective of doubling the assets dedicated to specific initiatives promoting energy transition or social cohesion
published as of 8 October 2018.

44 Stewardship Report 2021

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In a similar way, we have worked closely withclients to develop appropriate products to
respond to their climate change investing needs.
We have prioritised the transition to a low-carbon
economy through an extended investment
offering of off-the-shelf and bespoke climate
solutions. Amundi aims to support investors
in the design, management, and monitoring ofEquityAlign Investments
to a Net Zero
Trajectory

their efforts to integrate climate change into
their investment approaches centred around
two major goals in constructing climate changerelated investment solutions: managing risks
and encouraging the transition.
This table shows the main strategies that wehave developed alongside our clients:

Fixed Income

Real Assets

Paris Aligned & Climate Transition Benchmark ETFs

Global Green Equities

Euro Bond Climate

European Climate Equities

Just Transition for Climate

Global Climate Multi-Asset

Finance theEcological andEnergy Transition
For and with impact

Global Sustainable
Infrastructure

Global Green Bonds

Green Real Estate

EM Green Bonds

Green Senior Impact Debt

Global Natural Resources
Water Energy Global
Resource

GRECO Green Credit
Continuum
Green Bonds ETFs

European Green Equities
ESG Thematic Equity ETFs:
New Energy, World Water

Amundi-AIIB* Climate Change Investment Framework* AIIB: Asian Infrastructure Investment Bank

45 Stewardship Report 2021

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➜ Our progress in 2021
Illustration 20: Accompanying clients in their Net-zero journey
In 2021, Amundi pro actively accompanied two major European insurers in their
Net Zero journey
By becoming signatory of the Net Zero Asset Owner Alliance (NZAOA), the two European
insurers strengthened and clarified their commitment towards a low-carbon economy. Amundi
played an active role by supporting the two insurers in becoming Climate Leaders in theirindustry:– Carrying out in-depth review of carbon emissions exposure of portfolios.
– Aligning portfolio objectives with those of the Net Zero Asset Owner Alliance Protocol.
– Setting guidance in engagement, carbon reduction, sectoral and climate solutions targets.

Insurer 1 - Net Zero objective in 2050 with the following 2025 targets:– Reduce the carbon footprint of its listed equity and corporate bond investment portfolios
by 25%, compared to 2019.
– Double its investments in renewable energy

Insurer 2 - Net Zero objective in 2050 with the following 2025 targets:– Reduce the carbon footprint of its equity and corporate bond portfolios by 30% by 2025
compared to 2018.
– Double the part of green investments between 2020 and 2025

Illustration 21: Accompanying client understanding of their Climate risks
In 2021, Amundi conducted a review of available
transition and physical risk metrics to evaluate
the exposure of existing mandates to climaterelated risks for a European pension plan. By
using transition and physical risk scores fromdifferent data providers, and by including inhouse methodologies, some risk areas wereidentified and reported to the client. This has led
to the implementation of new guidelines on bothtransition and physical risk when the concernedclient renewed their mandates later in the year.

46 Stewardship Report 2021

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In addition to seeking direct client feedback on the quality of our products and services, we also
use annual third party surveys including a “customer recommendation index” which is rolled out in
Europe and Asia at present. On that basis, we believe that we manage and deliver funds that fullycomply and respond to client needs.

➜ Our progress in 2021
Illustration 22: Actions taken from customers’ survey outcome
In 2021, the results from our annual clients’ survey highlighted a need for new thought
leadership publications related to ESG dimensions. Following this outcome, Amundi decided
to launch a new publication series entitled “ESG Thema”. These short papers aim to shedlight on Amundi’s ESG expertise, by presenting key concepts, sectoral analyses, regulatory
evolutions, and potential solutions for investors. Moreover, these easy-to-use pieces provide
analytical frameworks to help investors understand sometimes complex issues around ESG
and responsible investing. For example, the third paper of the ESG Thema series provides
an original guide to help investors integrate Net Zero targets in their portfolios, through five
“key ideas for Net Zero”. Another paper provides an overview of the current ESG disclosure
requirements for companies and seeks to identify best practices to increase the ambition andharmonization of corporate sustainability reporting.
Through these ESG Thema papers, Amundi has also been able to demonstrate its capacity toreact quickly following important ESG-related news or events, and analyse their consequences
for investors. For example, we have published a paper shortly after COP26, identifying themain sustainability and climate pledges taken by states and corporates, and the opportunities
these could represent for institutional investors.
These papers are now part of Amundi Institute’s most consulted publications, proving that
there is a clear interest from clients and the financial industry at large to stay informed on
rapidly evolving ESG topics.

Furthermore, we ensure that our contractual
relationships with clients explicitly set out ourdelivery of ESG and stewardship on their behalf,
and we work diligently to deliver against thoseclient requirements.
Risk management is an important part of ourstewardship approach. Two major risks appeared
over the last two years: in the form of a healthcrisis and more recently a geopolitical one. The
Covid-19 pandemic was a global event without
modern precedent. It became an economiccrisis which was reflected in the sharp drop
in asset prices and an increased volatility on
financial markets. Amundi managed the crisisand continued normal operations thanks tothe actions taken in terms of risk management,
human resources and IT to monitor the liquidity ofour portfolios and to enable all Group employees
to work remotely or on site, as appropriate
throughout the year, under satisfactory andsecure conditions. Maintaining this high levelof service to our clients was achieved throughrapid communication regarding the continuityof our service and ability to provide support,
as well as the implementation of digital tools
to support partner networks in understanding
the market environment and conducting sales
activities remotely.

47 Stewardship Report 2021

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2. Reporting openly and transparently to our clients
Amundi welcomes the opportunity to be fullytransparent and open with its clients, andmaintains clear channels of communication.
This includes providing investors with awealth of documentation on its Responsible
Investment approach, Engagement and Voting
policies and reports and other ESG-related

reports. Furthermore, Amundi is able to provide
both generic and customised ESG reporting
depending on individual client needs. We
include a list of the documents available andsample reporting in the appendix section.

➜ Our progress in 2021
Amundi published its first integrated Climate Report, aiming not only to answer to the French
Energy Transition for green Growth Act’s requirements and to the recommendations of the
Task Force on Climate-related Financial Disclosures (TCFD), but to become a key reference
document to provide a comprehensive summary of Amundi’s ESG and Climate initiatives
accessible to all stakeholders.

3. An external certification to ensure the quality of
our key internal processes and reporting capabilities
An annual ISAE 3402 audit is carried out
by PricewaterhouseCoopers. This provides
independent assurance in relation to our key
internal processes and reporting capabilities,
with a particular focus on our ability to deliver onbehalf of clients and in line with our agreements.

This bolsters our confidence that our work toassess the fairness of our reporting, and then to
apply controls and checks, does in fact deliver
fair and honest reporting on our activities to thebenefit of all our clients.

48 Stewardship Report 2021

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Principle 7
Signatories systematically integrate stewardship andinvestment, including material environmental, social andgovernance issues, and climate change, to fulfil their
responsibilities
The environmental, social, and governance (ESG) issues that companies face have a major impact
on society. They also have financial consequences for businesses, both in terms of risk andopportunities. Amundi aims to better understand these factors and to incorporate those risks
and opportunities when making its investment decisions on behalf of our clients. We detail inthis section how ESG criteria are incorporated into our management processes for ➊ corporate
listed assets, ➋ sovereign debt issuers, ➌ real assets as well as ➍ delegated funds. In addition
to the ESG analysis, Amundi applies a strict exclusionary policy explained hereafter. Finally, we
provide a focus on the enhancing investment integration over 2018-2021.

1. ESG analysis consolidates value creation_____
Amundi believes that ESG analysis consolidates
value creation as it provides a holistic
understanding of the overall company. Thisbelief has led us to integrate ESG criteria acrossall our active management processes, and to
implement an engagement policy. Underlying
ESG integration is the conviction that a strong
sustainable development policy enables issuers
to manage their regulatory and reputationalrisks better and in addition to improve theiroperational efficiency. By integrating such
issues fully, investors can therefore take into
account long-term risks (financial, operational,
reputational, etc.) and also fully exercise their
responsibility to clients and society as a whole.
For this reason, we believe that the aim of ESG
analysis is to raise awareness and encouragecompanies to do business with a sustainable
development approach, while assigning theman ESG rating. Our analysis makes it possible
to incorporate risks related to the company’s
activity, enabling us to reduce the overall levelof risk our clients face.

Therefore, we 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.

49 Stewardship Report 2021

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Graph 6: Rating of corporate, supranationals & agencies issuers

1. Criteria & Weights

2. ESG rating calculation

3. Qualitative input

Using a Best-in-Class approach,
the ESG analysts are in charge of:– ESG Rating are calculated
by using the ESG criteria
and weights assigned by the
analysts and combining the
ESG scores obtained from ourexternal data providers

In addition to ESG ratings, our
ESG analysts integrate qualitative
input retrieved from:– Strict calculation process– ESG data/research from external
providers and open source
materials– Defining the most relevant
criteria for each sector– Weighting the criteria and theunderlying data by sector– Assessing the quality of data
providers & improving themethodology

Qualitative Approach– Monthly update– Meetings with companies– Meetings with industry experts– Over 10-year track record in
ESG ratings

Quantitative Approach+13,500 issuers ESG rated

Qualitative Approach

A

B

C

D

E

F

G

ESG coverage spans all main equity & fixed income indexes
Source: Amundi as of November 2021

2. A proprietary ESG rating available to all portfolio
managersa. Overview of the ESG rating
The outcome of the E, S, and G ratings
aggregation and analysis of a range of sources is
our proprietary rating, now available for 13,500
issuers16. The ratings range from A to G, with G
as the worst. Different funds are permitted tohold different stocks, but almost all portfolios(the only exceptions being some passively
managed portfolios) are required to exclude G
rated stocks.

16. As of end of September 2022

50 Stewardship Report 2021

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Graph 7: From the ESG score to the ESG rating scale# stocks# stocks
250

G

F

E

D

C

B

A

ESG Rating Scale200

is based on a letter rating scale from A to G (where A
is the best, and G is the worst). The ESG Rating is thetranslation of the Z-score into an alphanumeric scaleof 7 segments from A to G.

150

ESG score
Weighted average of the issuer’s E, S and G scores. Eachpillar is the weighted averaged of the scores obtained
from each criteria that the E, S, or G pillar is composed of.

100
50Single ESG rating per issuer,
applicable to all asset classes

0
-3.1
-2.9
-2.7
-2.5
-2.3
-2.1
-1.9
-1.7
-1.5
-1.3
-1.1
-0.9
-0.7
-0.5
-0.3
-0.1
0.1
0.3
0.5
0.7
0.9
1.1
1.3
1.5
1.7
1.9
2.1
2.3
2.5
2.7
2.9
3.1

G-rated issuers are assessed manuallyand submitted to the ESG rating committee
for examination and approval.

Z-Scores
Z-Scores* Calculation methodology which transforms ESG criteria into Z-scores (deviation in the security’s scorecompared with the average score for the sector, by number of standard deviations).

Issuers are monitored on an ongoing basis andany news on controversies is factored in the
ESG analysis. Controversy analysis can leadto a change of rating either at the level of therelevant criterion or at the final ESG rating level.
Our proprietary Stock Rating Integrator tool

also enables total transparency. At any time,
the rating assigned to a given issuer can be
explained using a flower graph based on thecompany’s scores on the various criteria. Hereis an example of an ESG rating of a company
displayed in the tool.

Graph 8: Example of an ESG rating of a company displayed in the tool
Audit & Control E

C Water management

Board Structure D

C Supply chain - Environment
6%

7%

ESG Strategy D

3%

7%

E

4%

Ethics C

19%

G
D

C
43%

B Boidiversity & pollution

C

4%

Remuneration C

6%

20%

ESG

C Emissions and energy use

5%

2%

7%

S
C

Shareholder’s rights D

9%6%

Access to medicine B

C Working conditions

3%
13%

C Supply chain -Social

D Product & customer responsability
C
Bioethics

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Stewardship Report 2021

In addition to the standard calculation of ratings,
an active and in-depth analysis is carried out
on a number of issuers selected by the ESG
analysts.
Such coverage of a company can be triggeredby several reasons:– specific requests from portfolio managers;

October 2022

– the overall level of exposure of Amundi to agiven issuer;– our annual engagement campaigns;– issuers with a particularly weak ESG rating
for a given criterion; and– the quarterly controversies screening.

b. A set up intended to provide the highest value to the clientsThe ESG analysis team is independent. It
works however closely with the investment
management and financial analysis teams.
This organisation ensures the quality and the
independence of the ESG analysis and opinions.
In addition, all G-rated issuers are validated
by the ESG Rating Committee, directly or
through the approval of the exclusion process.
The separation of the ESG analysis allows ourportfolio managers to benefit from different
skills sets (both financial analysis and ESG
analysis) and to make their investment decisions
independently. Except for G-rated issuers,
our portfolio managers have the final say on
whether or not they should invest in a given
issuer’s securities.

We believe this structure provides the highest
value to our clients, who can benefit from thefull expertise of our ESG analysis, financial
analysis and investment management teams,
collectively and individually. Amundi regards
its active engagement approach as an integral
part of its ESG integration policy. One aim ofengagements is to assist companies in making
progress in terms of our ESG ratings analysis.
This enhances their impact on the real world,
and also widens the investment universe for our
portfolio managers and for our clients.

3. ESG analysis and rating across asset classes__a. Amundi proprietary ESG rating at company level, applying to both
listed equity and debt
Our ratings approach is at the company level andapplies to equity and fixed income instruments
alike. This approach is reflected in Amundi’semphasis on double materiality. A negative
real-world impact of an issuer should not bediminished in importance just because the asset
class in question may be less financially sensitive
to that impact.
Our ESG analysis framework is comprised of
38 criteria, of which 17 are cross-sector criteria,
common to all companies whatever theirbusiness sector, and 21 sector specific criteria.
These criteria were designed to either assess

how sustainability issues might affect the issuer
as well as the quality of the management of thisdimension. Impact on sustainability factors aswell as quality of the mitigation undertaken are
also considered.
These ratings, and the calculations of the 38
criteria that are relevant for arriving at the
ratings, are available to all of our portfolio
managers through their investment portfolio
management software tool. This enables themto integrate sustainability issues into theirinvestment decisions and apply any relevant
constraints for their portfolios.

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Our ESG analysts also annually review theapplication and weightings of the 38 criteria toeach sector. This enables us to maintain quality
and ensure that we seek to continuously improve
our analysis by considering the materiality of
the criteria and their weights. Our ESG analysts
are sector specialists and within each sector aretasked with:– Tracking trends (macroeconomic, regulatory,etc.)– Establishing weights based on the materialityof ESG factors– Interviewing a representative panel ofcompanies– Writing sector analysis reports– Selecting the most qualified external data
suppliers meeting the definition of ourcriteria– Defining the weights to each data supplierthat represent the level of contribution ofeach supplier’s ESG score to the final ESG
score of an issuer.
A similar approach is applied in a tailored way
to other asset classes to reflect their particularimpacts.

b. The specific situation of sovereign debt issuers
With regard to sovereign debt issuers, ourapproach again seeks to consider the main
ESG issues to which an investor is exposed.
We seek to assess the ESG issues embedded
in governments’ current and past policies,
which could be reflected in a country’s ability
to reimburse its debt in the mid- to long-term,and so thus represent a risk for investors. We
also seek to assess how countries handle themajor sustainability issues that contribute to
the stability of global society. Our methodology

relies on about 50 indices or factors, each ofwhich represents one ESG issue. These areconstructed from an external data provider thatbases them on information from various sources
including the World Bank and the UN as well as
proprietary databases and expert scorecards.
These are combined into an Amundi ESG
sovereign index, grouped into eight categories
under the pillars E, S and G:

Graph 9: Examples of thematics within each pillar

Environment

SocialGovernance

Climate Change
Natural Capital

Human Rights
Social Cohesion
Human Capital
Civil Rights

Government
EffectivenessEconomic
Environment➜ Our progress in 2021
Amundi implemented in 2021 a dedicated in-house ESG approach to cover Supranational
entities and Agencies. This approach was designed in order to improve our coverage, especiallyon fixed income portfolios. It relies mainly on data collected at both corporate and sovereignlevel from third-party data vendors.

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c. Real assets
With regard to other types of instruments
or issuers, we have developed specificmethodologies to assess the ESG qualityof different instruments and issuers. Thesemethodologies respond to issues arising fromthe nature of the relevant instruments or
because our existing external data providers do
not provide relevant coverage.
These methodologies cover private equity,
private debt issuers, impact investing and realestate, as well as specific instruments such as
green or social bonds. Each methodology is
specific, but they all share the same target: theability to anticipate and manage sustainability
risks and opportunities, as well as the ability
to mitigate their potential negative impacts onsustainability.

By integrating real estate, private equity, private
debt, green infrastructure, multi-management
and social impact investing expertise within one
division, Amundi Real Assets can offer investors
diversification opportunities and long-term
returns. Through our proximity to market players
and our regional presence, we are committed
to facilitate access to responsible investment
real assets solutions and to measure the impactof these solutions on society, people and theenvironment. The limited nature of the real
assets investment universe and the manageable
number of portfolio positions in each of thefunds enable our investment teams to maintainclose direct contact with all our counterparts.
They are thus also better equipped to influencethese counterparts on ESG issues and toensure that they comply with their sustainable
investment commitments.

Amundi has developed a significant real assets
activity, totalling more than EUR60 billion asof end of December 2021.

➜ Our progress in 2021
Building on the drawing up of charters by asset class, Amundi decided in 2021 to introduce by2022 an ESG charter common to all of Real Assets' areas of expertise.
In parallel, in 2021, we have strengthened the Real Assets division's ESG governance by
creating a dedicated ESG team and setting up a community of employees who are involved in
ESG issues within each area of expertise: the "ESG Front Runners”. It provides an opportunity
for ongoing exchange on regulatory changes and how to interpret them, and for sharing of
information and best practices between our areas of expertise.

Another significant feature of Amundi Real
Assets is the existence of an unlisted social
impact strategy. The team in charge has over 10
years of experience and is responsible for thecreation of the Amundi Finance et Solidarité
fund.
Amundi Real Assets’ commitments to a moresustainable world are articulated across threemain pillars:– Acting for the climate– Increasing transparency– Aligning the interests of all stakeholders
Amundi Real Assets division benefit froma 5-person ESG team dedicated supportedby Amundi Responsible Investing teamand a 28-person ESG Front Runners team(management, marketing, layers, etc), whochampion ESG issues.

54 Stewardship Report 2021

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Graph 10: Amundi Real Assets AUM (EUR
million) as of December 31, 2021

PrivateEquity1 000

Social Impact
investing440
Green Infrastrusture427

Private debt
8 500

Multimanagement
10 400Real Estate
41 900- Amundi Private Equity’s (PEF) ESG
approach
Working with the ESG team, Amundi PEF has
integrated an ESG approach into its investment
process. It is characterised by the systematic
deployment, upstream and downstream of theinvestment decision, of an exclusion process, an
ESG rating process, and a process to support
companies with regard to ESG issues over theentire holding period of the investment. All
potential investments for an SRI fund mustcomply with the exclusion policy and undergo
due diligence processes conducted by Amundi’s
ESG analysts (or under the analyst’s supervision
if the due diligence is outsourced), who assigns
a rating prior to the investment. The process isfurther outlined in the chart below.

A rigorous investment process
Initiative
Associate Director

Origination- A methodical dealflow selection resulting from a network of local banks andindependent business providers and a proactive approach

Weekly meeting

Initial review- The initial review helps eliminate deals that do not correspond to our strict
investment criteria; the ESG exclusion policy is applied- Pre-selection according to ESG criteria

Financialand strategic
analysis- A detailed analysis is conducted by the team in charge, based on:• An assessment grid used to detect risks and opportunities• The use of external specialists for in-depth due diligence

ESG analysis- An ESG analysis eliminates companies failing to comply with the selected ESG criteria- Interview with an Amundi non-financial analyst and recommendations made atgovernance body level

Decision- The decision to invest is made by a committee, based on the detailed analysis of the
project, the risk matrix and the due diligence review by a due diligence mentor• The risks matrix, made by risks and compliance – ethics teams, insures that theinvestment is realised within the framework of financial regulations and of the rules ofconduct, especially concerning conflicts of interest

Closing- Each investment is made and followed up in liaison with the cross-functional teams(Financial Control and Operations, Risks and Compliance)

Pre-due diligence
Investment Committee

Investment Committee
post-due diligence

Post-closing- Active role in Supervisory Board- Implementation of corrective measures post-closing

The investment committee's decisions are made exclusively by the management team(with opinions from the Risk and Compliance departments)

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- Private debt
Taking ESG criteria into account has been an integral part of the private debt investment processsince inception in 2014, from the investment selection phase through to the maturity of the loans
and bonds. The general principles common to all the areas of expertise are presented below:

First level ESG
NO GOSecond level ESG
validation

Supportand encouragement
to improve ESG
practices

Origination- Investment opportunities received by the Private Debt investment team and discussed
during the weekly pipeline review meetings- Systematic participation by a member of the ESG team in pipeline meetings

First filter- The initial review is used to eliminate any cases that do not meet the strict investment
criteria- The ESG exclusion policy is appled or, in the case of pre-existing ESG rating, G-rated
cases are automatically excludes

First
submission
to committee- An analysis of the major aggregates (credit profile, transaction) is conducted on
the basis of information provided by the company’s management- It goes to committee after the step, the ESG exclusion table/score being includedin the document

ESG analysis- If there is no rating in the Amundi data base, ESG questionnaire sent by the ESG analyst
and response by management or the person responsible for ESG matters- The ESG analyst formalises an analysis document with the conclusion in the form of acolor code

Secondsubmission tocommittee- In-depth credit analysis document including the ESG analysis (or ESG rating)- Second submission to committee to validate the credit profile. The ESG team has apermanent seat on the investment committee

Final validationby committee- Negociation of loan documentation and price - integration of ESG informationcommitments, structuring of Sustainability-Linked Loans mechanisms if relevant- Definition of monitoring indicators and presentation to the issuer by the ESG analyst

Follow up- Follow-up at least once a year and ESG reporting sent to subscribers- Remedial actions for any ESG deviations

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- Fund of funds – private assets
ESG in one of the pillars of our fund of funds
due-diligence process, alongside financial,
operational and legal aspects. In our selection
process, we analyse ESG practices at thecorporate or General Partnership (GP) level and
ESG integration in their investment process. This
analysis is based on our knowledge of current
best practices.
We also pay special attention to the quality
and scope of the ESG reports. Beside theintegration of ESG criteria in our selection
process, we also want to make our voice heard
through continuous dialogue and engagement.
We systematically include ESG requirements
within a side letter agreement with GPs and we
stipulate specific ESG reporting requirements.

energy part for which we prefer to apply more
stringent requirements by opting for a tailormade criterion. Thus, each country is evaluateddifferently depending on its energy regulations
and, more specifically, the regulations which
apply to the building as determined by its yearof construction.
Assessing the responses makes it possible
to score the assets on a scale of 100 for theirenvironmental and social performance. The
score assigned to the asset for each criterion
appears in blue in the diagram; The weighted
average reflecting the asset’s overall score isshown in the box. It is also possible to put theasset in context compared against the internalscore (ranging from A to G, where A is thebest score). We also use the help of SINTEO, aspecialist environmental consultant.

- Real Estate
Client assets in real estate are mainly invested in
office properties across European prime cities.
Amundi is a leader in this market segment
and invests in over 1,100 assets. The real estate
division has developed a comprehensive
Responsible Investment Charter that details
its ESG approach. The assessment of theenvironmental and social performance of a realestate asset is based on the analysis of 8 pillars.
The presentation of these results is organised into
8 areas and each question falls under one of thesecategories:• Health/Well-being• Energy• Transport• Water• Waste• Pollution• Sustainability ofequipment• Land use andecology

Environmental and social performance
Scoring example :

G

F
14

0

71/100E29

Pollution
59%

D
43

C
57

100 %
50 %

B
71

0%
Energy65%

Materials
81%
Water
78%

The environmental and social mapping isdesigned to provide the level of detail necessary
to identify the key factors affecting each
asset. It is carried out via a 56-question survey
based on the BREEAM17 In-Use Part 1 standard(evaluation of the intrinsic performance of thebuilding and installed equipment), except for the

17. BREEAM: Building Research Establishment Environmental Assessment Method

Transport
83%

86

100

Health and well-being
52%

Land use
100%
Waste
100%

A

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➜ Our progress in 2021
In 2021, a review of Amundi Real Assets' ESG strategy was conducted. The aim of this study
was to analyse the ESG practices of our various teams, to compare them with market practices
and to identify avenues for improvement through the recommendations made. The conclusionof this review was presented to the management of Amundi Real Assets at the end of 2021 andled to the gradual implementation of a new organisation on ESG-related issues.

d. Delegation of fund management to third parties
Amundi sub-contracts the management of EUR
47.5 billion of assets to external fund managers.
As part of our routine investment due diligenceof delegated managers, we take a two pronged
approach. In the first instance, we perform aqualitative evaluation based on the Responsible
Investment policy of the organisation (25%),
its responsible investment approaches (best inclass, ESG integration, impact, etc.), including
the exclusion policy (25%) and finally on thefund/delegation itself (50%).

Both these qualitative and quantitativeevaluations of a manager’s approach to ESG arepart of a broader due diligence process of thefund/mandate and the company (operational
due diligence, quality of investment process,quality of teams, performances, etc.). When we
delegate funds to managers, we also send themmonthly a list of stocks to be excluded.
When Amundi just performs a fund hosting
function, then the exclusion list does notnecessarily apply.

As a second step, in order to verify what wehave learned from the qualitative evaluation,
we calculate a quantitative ESG score, using the
proprietary ESG methodology of Amundi.

Illustration 23: Focus on fund of funds due-diligence process
ESG is incorporated at every step of the process:1. Qualitative evaluation
We send a qualitative questionnaire to the manager of each external fund. This questionnaire
is Excel based and runs to over 100 questions. We systematically score the responses to form
a qualitative view at three levels: firm, strategy and fund.

2. Quantitative evaluation
We source the holdings of external funds on a quarterly basis and integrate this data with the
proprietary ESG scores for the securities and issuers. This enables us to calculate an ESG scorefor each fund consistent with our internal Amundi process.

3. Integration
We integrate these two scores in our investment due diligence in a dedicated section on ESG,
scoring each fund based on the combination of our quantitative and qualitative evaluations.
The overall rating and conviction level of the fund will be influenced by the ESG evaluation.

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4. Portfolio construction
When constructing solutions for clients, Fund of Fund portfolio managers, seek to “Beat theBenchmark” in terms of ESG Score. To do this they use:
➊ the “look through” or “transparency” to underlying securities in Alto to score internal Amundi
Funds and delegated funds and mandates for ESG.
➋ For ETF’s the ESG score of the reference index of each ETF is used as a proxy.
➌ The ESG score of external funds as per section 2 above is integrated in our front officesystem, Alto

Case study 5: Action taken in the context of qualitative and quantitative scoresinconsistency
Early 2021, a material inconsistency has been
identified between the quantitative and thequalitative portfolio’s scores (2 rating-letter
difference or more).
In February 2021, the inconsistency has beenhighlighted to the firm in question, with planned
follow-up discussions to dig deeper. In March
2021, the firm has been contacted to advise ofa redemption of circa EUR 10 million because ofboth a weakening performance trend and ESG
concerns. In the meantime, our overall allocation
to this firm has fallen by one third of AUM today.

Case study 6: Action taken in the context of a poor ESG profile compared to peers
During a process review, a positively rated portfolio scored poorly in ESG terms versus peersin the same asset class.
The firm has been contacted to be informed about Amundi ESG approach and potential
consequences considering that Amundi portfolio managers have ESG performance objectives.
As part of this discussion, it has been highlighted that their Emerging debt fund scores theweakest of the four "Buy Listed" funds on the same asset class using the Amundi Quantitative
ESG Scoring. The firm has been informed of the risk to loose assets at the margin to equivalently
rated funds that score better from an ESG perspective.
We encouraged them to consider ESG rating to rate their holdings and identify potentiallycontroversial issuers. In the interim, the firm has made token efforts to address their ESG
shortfalls. Meanwhile, our allocation to this fund has fallen to date.

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4. Exclusionary approach ___________________
a. A targeted exclusion policy
Amundi applies a strict exclusion policy of
the worst ESG-rated companies across all
actively managed portfolios. We regard suchtargeted exclusions as arising directly fromour fiduciary duty to protect clients’ interests.
These exclusion policies apply to all our active
investment strategies and lead us to exclude
companies that do not comply with our ESG
policy, international conventions, internationallyrecognised
frameworks,
andnational
regulations. Our exclusion policy is kept underactive consideration, and is formally reviewed
annually and approved by the ESG Committee.
The current exclusion policy bars any of ourfunds from investing in:– Issuers involved in the production, sale,storage or services for and of anti-personnel
mines and cluster bombs, prohibited by the
Ottawa and Oslo treaties;– Issuers involved in the production, sale orstorage of chemical, biological and depleted
uranium weapons;– Issuers that violate, repeatedly and seriously,
one or more of the 10 principles of the Global
Compact.
In addition, Amundi applies specific sectoral
exclusions to controversial industries, namely
coal and tobacco. These sectoral exclusions
apply to all actively managed strategies overwhich Amundi has full portfolio management
discretion and always subject to applicable laws
prohibiting their implementation.
Those exclusions apply unless clients specificallyrequest otherwise in the context of individual
mandates or tailored funds (or fully passive
strategies).

Illustration 24: Sectorial exclusions policy
Thermal Coal18
Amundi has committed to reduce exposure to coal in portfolios with a formal coal exit in OECD
countries by 2030 and 2040 for the rest of the world, in line with the Paris Agreement (seePrinciple 9 for more details on specific engagement on coal).
The following companies are already excluded from all active strategies:– Any companies developing or planning to develop new thermal coal capacity along theentire value chain (mining, production, utilities and transport infrastructure).
– Companies generating more than 25% of their revenues from coal mining, or with annual
coal extraction of 100 Mt or more, without having declared an intention to reduce this.
– Companies with revenues from coal mining and coal-fired electricity production equal to or
greater than 50% of their total revenues.
– Coal-fired power generation and coal mining companies with revenue between thesethresholds of 25% and 50% which do not have an improving energy transition score.

18. This policy has been revised in 2022, for more information see Amundi RI policy

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TobaccoAs a signatory of the Tobacco Free Finance Pledge, in 2020 we further strengthened our
tobacco exclusion policy.
This applies as follows:– We exclude any investment in companies that manufacture complete tobacco products(applying a revenue threshold of 5%).
– We cap our ESG rating of an issuer with more than 10% of its turnover from tobacco (thisincludes suppliers, manufacturers and distributors) at E. As a result, such companies are
excluded from our SRI funds range, which is historically subject to the exclusion of issuers
rated E, F or G.

➜ Our progress in 2021
In the context of the new Amundi “Ambition 2025” plan, defined and released in 2021, Amundiannounced that by 2022, an exclusion policy will be applied to unconventional Oil & Gas
activities, for the companies that derive more than 30% of their revenues from these activities.
– Amundi published its policy on unconventional oil & gas in March 2022. We will divest fromthis sector at the end of 2022.

Case study 7: Exclusion of an issuer based in Thailand
Amundi have monitored an issuer, based in Thailand, that had a project to develop a new coalunit.
We did engage the company as the project was in pre-permit status to explain them our policy
regarding coal developers. When the project has been revised to be permitted as of June 2021,
the ESG rating committee decided to exclude the issuer from our active investment universe.

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b. The specific case of non-ESG passive funds
Our exclusion policies already apply to all our
actively managed funds and ESG ETF products,
but do not apply to the non-ESG passive range.
To increase the scope of application, Amundi’s“Ambition 2025” plan includes a commitment
to extend our ETF ESG products by 2025 to aminimum of 40% of our ETF range.

In parallel, for issuers held in non-ESG passive
portfolios but excluded from our active and ESG
ETF universe, Amundi uses its engagement andvoting capabilities to express its concern. Where
insufficient action is being taken on reducing
harm and/or transitioning to a sustainablebusiness model, Amundi votes against thedischarge of the board or management or
the re-election of the Chairman and of some
Directors.

Case study 8: J-Power (Japanese producer of electricity)

Since Spring 2021, Amundi is co-lead on J-Power, excluded from our active universe, for the
AIGCC utilities engagement program (Asia Investor Group on Climate Change). Amundi
recognizes J-Power’s effort on improving and enhancing ESG disclosure including the TCFD
recommendations on climate scenario analysis, together with quantitative financial impacts
and target timeline that includes 2030 as midway and 2050.
Nevertheless, we asked J-Power– to upgrade its targets to be aligned with the goals of the Paris Agreement– to upgrade its decarbonisation strategy and have a strategy relying on economically viable
and feasible technologies– to include KPIs based on the achievement of this climate strategy in the top management
incentive plan.
This engagement has started in 2021 and does continue in 2022. As of December 31st, 2021 thecompanies did not upgrade its strategy19.

19. In 2022, Amundi has co-filed 3 resolutions with ACCR : https://www.accr.org.au/news/strong-call-by-j-powershareholders-to-strengthen-decarbonisation-strategy/

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5. Enhancing integration of ESG considerations into
investment activities: 2018-2021 ESG plan and climate
developments
To fulfil 2018-2021 ESG plan objective that all
actively managed open-ended funds maintaina higher ESG score than their benchmark
index, Amundi worked to enhance the skills
and processes of our investment teams. All

investment hubs upgraded their investment
processes in order to move from exclusionary
screening toward full active and systematic
integration of ESG factors in their respective
management platforms.

a. Enhancing integration through innovation
To facilitate this, we have implemented a Straight
Through Processing tool that enables managers
and risk control teams to access companies’
ESG ratings, alongside equity and credit ratings.
This Stock Rating Integrator tool guarantees theconsistency and transparency of information at
all times. A security’s rating may be justified at
any time using a decision tree based on scoresassigned to the security for each of the reference
system’s criteria.
The following ESG data is now uploaded as
standard into the ALTO system used by all ofour portfolio managers:– ESG ratings: overall rating and component
ratings (E, S and G pillars), as well as allunderlying criteria.
– Energy Transition ratings– Carbon data: CO2 scope 1, 2, 3; CO2 reserves;coal shares; etc.
– All data and information relevant to client
specific exclusion lists or exclusions criteria(such as alcohol, weapons, fur producers,etc.).
This ALTO ‘Sustainability Analysis’ module is anasset allocation module that displays not only thedata for each security held in a portfolio but also

calculates the average ESG rating of a portfolio
and compares it to the benchmark or universeof reference. Amundi portfolio managers thus
benefit from our internal ESG ratings, and at
all times know the financial and ESG ratingsof the securities held in their portfolio, and its
benchmark index, if any. Portfolio managers
monitor the financial and ESG profiles of theissuers in which their funds invest and can liaise
with the ESG analysts to get their insights toassist with buy, sell or hold decisions.
Depending on the investment strategy andthe ESG approach of the fund, the portfolio
manager may focus on:– The overall ESG rating of the issuer. For
example, SRI portfolio managers take bothfinancial analysis and ESG analysis of anissuer into consideration before making a buy
or sell decision. In most cases, this translates
into a matrix of decision across both financial
and ESG factors. The lower the ESG rating,the higher confidence in future financial
performance is needed.
– The rating on specific criteria. For example,
in our Green Bond strategies we focus on theenvironmental and energy transition subcriteria in order to assess the ability of anissuer fully to embrace the energy transition.

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b. Different asset classes and strategies involve differentiatedapproaches
Naturally, the weighting of the ESG Scores andRatings within each investment process varies byasset class and by strategy. Given our particularfocus on climate change issues, our approach inthis area is especially developed.

➜ Our progress in 2021
In the course of 2021, a specific approach of climate issues has been developed.
While the approach is under continuous research, work analysis and enrichments, to date, we
use scenario analysis to:– Estimate the impact of CO2 regulations ahead of their implementation in order to anticipate
potential disruptions to investment cases– Stress test the outlook for different types of activities under a carbon-constrained world.
As an illustration of the latter, we compare trends between the International Energy Agency’s
IEA 1.5°C scenario, the Sustainable Development Scenario (which factors in a carbon constraintaligned with objectives set under the Paris Agreement) and the International Energy Agency
base case scenario. This allows us to identify which activities face more upside/downside as
regulators tighten CO2 regulations. We draw heat maps by sector to take into account risksboth at the top-line level (price/volumes) and bottom-line (CO2 costs). For instance, in the oil &gas sector, some activities appear more at risk than others, with the modelled downside muchgreater for oil prices (30% lower in IEA SDS than in the base case) than for gas (6% lower inEurope). We then compare the exposure of issuer portfolios against these heat maps.
We try to use Net Zero 2050 and 2°C scenarios modelled by different institutions or by issuers
themselves in their TCFD (Task Force on Climate-Related Financial Disclosure) reporting toincrease our understanding of areas of uncertainty. After this exercise, we may end up having
a different opinion on the sustainability benefits of certain technologies and their contribution
to the low-carbon transition; but overall, we consider that using scenario analysis allows us
to go a step beyond the initial carbon-intensity analysis of sectors, activities and issuers in
our understanding of supply and demand shifts caused by carbon constraints. For instance,
scenario analysis allows us to understand the likely pressure from the ramp up of electric carson the supply of key battery materials such as nickel. This is not captured by current carbon
footprint methodologies.

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Principle 8
Signatories monitor and hold to account managers and/or
service providers
Amundi continually monitors the market for developments and to ensure access to quality
information. This ensures we are aware of increases in coverage and scope of the ESG data thatis available, including making sure we have access to innovative products, including raw data
and forward-looking assessments.

1. Data providers___________________________
Amundiconstantly
monitors
ongoingdevelopment projects at important andinnovative ESG data providers. Outlier data on
individual companies are also checked. As wellas this ability to cross-refer, the use of multiple
data providers has several additional benefits:– It allows for a greater overall coverage ofissuers by combining different footprints(some providers have better coverage ofparticular regions / sectors / asset classes).
– As data providers take different approaches
to analysing a particular criterion, the use ofmultiple data providers’ information gives
the ESG analysis team a 360° view on critical
ESG topics and relevant issuer behaviour.
– It gives Amundi access to more frequent
analysis updates, as each data provider
updates their analyses according to different
schedules.
We monitor controversies on companies andsurvey views amongst the team to ensurethat our ratings reflect the current reality. ESG

analysts have the ability to override any company
rating if it does not reflect their judgement. In
the case that such an override would lead to an
exclusion, the decision is made by the Ratings
Committee.
We also continuously monitor the quality of its
ESG research and data from external sources.
This monitoring includes an automated quality
check (set out under Review and assuranceof our ESG approach), as well as an ongoing
qualitative check from our ESG analysts, who
are specialists in each of their sectors.
Comparing the data is crucial in order to assess
the quality of the underlying information that
we use for our strategies. Typically, if ESG or
climate-related data gives us very different
outputs, we observe these discrepancies, andconduct a deeper analysis in addition to ourprincipal ESG analysis. Sample ESG data arestatistically verified internally at high level toassure their consistency.

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On a formal basis, the ESG Method and Solutions
team and the ESG Research Team analysts carryout the following actions, producing annual
reports for consideration by the ESG Ratings
Committee:– Complete annual review of each major
ESG supplier and production of a detailed
assessment;– Summary table of supplier offers in relevant
ESG categories, updated regularly andincluding an assessment of services;– Monitoring table of regular supplier meetingsand discussions, including the main points
covered; andOctober 2022

– Annual supplier assessment report updated
by the ESG Analysis team, integrating theviews of different analysts on all ESG data
suppliers.
Amundi conducts an annual review of its main
ESG vendors and their offers (ESG ratings,
climate, controversies, etc.). Amundi also haveregular calls and meetings with those vendors tokeep up to date with the latest methodologicaldevelopments and to provide feedback on
their services and data, including any potential
shortcomings.

Illustration 25: Methodological issue with one of our ESG data providers
In 2021, we faced an issue due to the lack of ESG rating coverage on Agency MBS by an
external provider, in particular for one of our Fixed-Income portfolios. Agency MBS representing
about 30% of the Bloomberg US Aggregate Bond Index (the benchmark of the concernedfund), one third of the index’ underlying was therefore not rated. As the fund was assessed
through a minimum coverage perspective amongst other criteria, this lack of rating coverage
unfavourably affected the fund, for which coverage ratio (calculated by the same data provider)
was computed on the basis of the full portfolio investment.
The data provider has been engaged in order to extend the scope of its ESG ratings data
coverage to Agency MBS initially and ultimately to all US securitized universe, as well as revisit
their coverage ratio to take into account their own lack of coverage in the ratio. A proposed
tactical action plan has been discussed, for which the data provider has started a feasibility
analysis. To date, such analysis is still under progress and Amundi is monitoring this engagement,
waiting for the data provider to come-back with achievable roadmap and timeline.

Illustration 26: ESG data delivery issues
In 2021, we encountered ESG data delivery issues with some providers, particularly in terms ofdata completeness in the files delivered, as well as file formats changes without notification.
We contacted these providers for correction by insisting on the importance of the stabilityof the data sent in terms of content and format. Following our engagement on this specificmatter, the data provider corrected the issue. To date, we’ve observed a better stability but
remain very attentive as part of our usual process to monitor closely all the data integration inorder to reinforce data quality control framework.

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2. Proxy advisors___________________________
Regarding proxy advisors, the team undertakes
regular due diligence meetings with ISS in
which we discuss issues such as timeliness andquality of their research and the application of
our voting policy, through monthly meetingsand mail exchanges. We provide feedback toproxy advisors on their methodology and any
potential gaps we observe in their analysis.

General meetings of companies’ part of a predefined "qualitative universe" (that takes into
account the financial materiality of the votes
at the fund level and aggregated), as well as
meetings considered significant due to theinclusion of specific proposals (e.g., shareholder
proposals on environmental or social topics) will
be systematically reviewed by the team.

The Voting & Corporate Governance team
maintains in all cases the ability to override thedefault recommendation made by ISS applying
the custom policy, in this case, the analyst will
signal to ISS any identified error.

Amundi accommodates certain custom voting
policies, provided for specific client mandates.

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ENGAGEMENT

Principle 9Signatories engage with issuers to maintain or enhance thevalue of assets“Engaging with purpose” is Amundi’s motto. At Amundi, engagement is a continuous andpurpose driven process aiming at influencing the activities or behaviour of investee companies
in order to support the transition of the economy to a more sustainable, low-carbon and inclusivemodel. For this reason, our engagement must be result-driven, proactive and integrated in our
global ESG process.

1. The aims of engagement__________________Engagement can have various aims that can bepresented in two categories:– Engage an issuer to improve both the way
it integrates the environmental and social
dimension in its processes and the qualityof its governance, in order to limit its
sustainability risks– Engage an issuer to improve its impact onenvironmental, social, and human rights
related issues, or other sustainability
matters that are material to society and theglobal economy, even though the financial
materiality to the issuer might not be clear
Engagement is different from corporate accessand traditional dialogue with a corporate.
Engagement has the aim of influencing theactivities or behaviour of investee companies
to improve ESG practices or its impact on key
sustainability linked topics.
More specifically, engaging implies having
a specific agenda and targets that focus on
real-life outcomes in expected timelines. Our
engagement activities seek to be impactful andadditional to the global effort of the financial
community. The engagement period varies

depending on the agenda, but the average
engagement period is approximately 3 years.
Amundi defines different milestones andengagement developments that are sharedinternally via our research platform, available toall investment teams. Formal assessments arecarried out, at least on a yearly basis.
We wish to have a collaborative, supportive,
pragmatic and ambitious dialogue with ourinvestees, to inspire a wide range of actions
that will benefit not only the issuers but to all
stakeholders. We truly believe that dialogue isthe corner stone of a sound, strong transition
towards a sustainable and inclusive low carbon
economy.
“At Amundi, Engagement is a continuousand purpose driven process”“To engage means to have a specificagenda, and targets that focus on real life
outcomes”

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2. The nature of engagement________________Engagement focuses on diverse sustainability factors, can take different forms, have different
outcome expectations, be triggered according to distinct rationale.
Amundi aims at reaching a balance between ambition and pragmatism in order to optimize theefficiency of its engagement and therefore maximize its impact. For this reason, while pursuing
the same midterm goal, our practices and demands are adapted to the maturity of a geography,
market, theme or issuer.

a. Engagement themes framing our engagement activity
Amundi engages issuers around 6 main themes:
1. Transition towards a low carbon economy
2. Natural capital preservation (ecosystem protection & fight against biodiversity loss)
3. Social cohesion through the protection of direct & indirect employees, promotion of human rights
4. Client, product & societal responsibilities
5. Strong Governance practices that strengthen sustainable development
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Illustration 27: Engagement is an effective tool to promote SDGs by influencing theinvestees to tackle those challenges and have a positive impact on their outcome.
In 2015, the United Nations Member States adopted the 2030 Agenda for Sustainable
Development that aims to provide a “shared blueprint for peace and prosperity for people andthe planet, now and in the future”20.
The Sustainable Development Goals (or SDGs) are a globally collaborative and relatively
comprehensive set of goals that apply to all countries and all actors. They include universallypressing issues such as poverty reduction, health, inequalities, environmental sustainability,
ethics, and economic growth.
Each SDG has specific targets and indicators to monitor global progress to achieve thesegoals. These indicators present opportunities for not only the public sector but also civilsociety, and private entities to engage in sustainable development in a meaningful way andcommunicate so accordingly.
The SDGs offer a framework to risks and opportunities for particular sectors and companies
and aid in analysis, strategy & product development.

ESG themes
Transition towards a low
carbon economy

Natural capitalpreservation

Social Cohesion

Client, Product &Societal Responsability

Governance Practices
for Sustainable
Development

20. https://sdgs.un.org/goals

Primary SDGs

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In 2021, we continued to engage with issuers within our 6 key themes.

b. Thematic or Contextual rationale triggering our engagement
Thematic Trigger

Contextual Trigger

When engagement is triggered by specific
key sustainability topics on which Amundiseeks to have a positive impact, such as theenergy transition, social cohesion, natural
capital preservation, social responsibility andgovernance’s accountability, we refer to it
as a “thematic trigger”. Based on the theme,
companies are selected according to howmaterial or salient the theme is to the company’sbusiness model and the company’s exposure to
relevant risks/opportunities.

“Contextual trigger” is when engagement is
triggered by specific contexts, situations of anissuer that lead Amundi to seek improvements
and/or remediation. It is a contextual
engagement that is triggered by a bottom-up,
issuer related approach.

Illustration 28: Contextual Engagement: engagement triggered by specificsituations
Whereas areas of engagement and themes are the same, the trigger of engagement is company
specific, as it has the ultimate objective to improve a company’s practices and ask for a smoothphase out of some activities.
Sometimes, engagement aims at highlighting sustainable opportunities that could deliver
additional benefits to companies and stakeholders. Whatever the subject, the aim is toencourage overall improved performance as well as to encourage companies to meet specificperformance benchmarks or impacts.
There are various triggers of contextual engagement.
They include :Pre AGM

Specificchallenges,
Risks,
opportunities

Specific
Asset
ClassesContextual
Engagement

Company
ESG
performanceControversies

Amundi
Specific
Policies

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Pre-AGM Dialogue
Amundi may undergo pre-AGM dialogue to encourage sounder corporate governance in linewith our Voting Policy. Apart from items directly linked to AGMs agenda, pre-AGM dialogues areoccasions to engage directly board members on key sustainability issues. Amundi encourages
board accountability in terms of social responsibility and climate strategy. For underlying
ESG issues, our ESG Research and Voting & Corporate Governance team may conduct jointcompany dialogues. Our voting reflects our overall approach to stewardship, meaning that weare committed to long-term relationships with the companies in which we invest, and strive tohave active dialogue with them. Amundi is committed to transparency and, where possible, we
inform issuers of planned negative votes.

Engagement around Specific Challenges, Sustainability Risks, or Opportunities
Contextual engagement can be triggered by specific challenges or sustainability risks faced by
the issuer or its sector, such as for example, the use for an industry of a specific metal which
extraction might imply human-right related challenges.

Specific ESG Performance
A company’s ESG performance (in general or based on our proprietary ESG Rating Tools) can
trigger engagement.
For laggards or companies that are improving, engagement will aim at triggering further
improvement of either the overall ESG performance or of the performance on one or two
specific criteria, ESG transparency and reporting, or at encouraging the adoption of bestpractices.
These types of engagements can take many angles. Engaging with a company may require
multiple angles and thus the above are not mutually exclusive.

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c. Established versus Emerging themes shaping outcome expectations
Established Themes
Established themes are themes that are
frequently discussed and well researched,such as climate and water risks, but where
corporate practices still need to improve.
While improvements on those themes are still
expected, companies and sectors are likely tohave a strong level of awareness around theimportance of the topic.
Regarding established themes, Amundi’s
objective is to push for the adoption of bestpractices.

Emerging Themes
Emerging themes are themes that are important
for the transition towards a sustainable, lowcarbon and inclusive economy but for whichawareness might remain limited and bestpractices are still emerging.
Regarding emerging themes, Amundi’s objective
is to raise awareness, create positive momentum
and contribute to establishing market standards.

d. A specific relationship with investees leading to specific targets
setting and modalities
Engagement provides investees with a uniqueperspective on industry best practices and canprovide constructive feedback to corporates,
especially for emerging topics. This is important
to us as it helps corporates to see the benefit ofengagement and not just consider it a useless
exercise.
Amundi engages investee or potential investee
companies at the issuer level regardless of thetype of holdings held. Issuers engaged areprimarily chosen by the level of exposure to thesubject of engagement.

As the environmental, social, and governanceissues that face companies have a major impact
on society, both in terms of risk and opportunities,
we consider that we need to assess the ESG
quality of an issuer regardless of our positionin the balance sheet (as a shareholder or abondholder). If ESG issues could have financial
consequences for businesses, those issues will
be considered by our investment professionals(equity or credit analysts, portfolio managers)in their valuation models and investment
processes.

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Illustration 29: Engaging with all companies, no matter their ESG performance, is
important to trigger adoption and improvement of best practices
Engagement angle for
ESG performance

How and why Amundi engages
on this angle

Definition

Engagement with Leaders

Discussions with leading issuers withstrong ESG performance to offer
them positive encouragement andincentivize them to remain a leader
through continued improvements.
“Best in Class” is a moving target,
it is important to recognize leaderswith strong performance but
continue encouraging them to make
improvements.

Engaging with leaders can help Amundi
get a better sense of current strong
practices and the direction the sector
is going to manage specific risks. These
key insights can help to set feasible
benchmarks for companies who may lag
behind.

Engagement with Improvers

Companies in the early days of their
ESG journey that lag behind peers but
express a strong desire to improve.

Amundi may work closely with thecompany to encourage improved
performance by helping the company
identify feasible yet ambitious short-termand longer-term targets that will lead to
improved ESG performance.

Includes companies with a limited
knowledge of ESG best practices suchas SMEs (small-medium enterprises) orcompanies in emerging markets.
Engagement with Laggards

Companies that demonstrate poor
performance on one or many ESG
criteria and lack the motivation to
improve.

Engagements target specific areas
where companies lag behind and aim toincentivize companies to make necessary
improvements.

Engagement for Better ESG
Disclosure

Companies that lag behind their peers
because of poor disclosure but notnecessarily poor practices (such as
in high yield, small cap, or emerging
market spaces)

Engagement to encourage transparency
aims to help companies develop theirreporting and become a more responsible
corporate actor. Having a clear, well
implemented, management frameworkfor ESG issues is key to demonstrate toinvestors that the company prudently
manages risks as measurement is the firststep of management.

Source: Amundi Asset Management

e. Engagement needs to adapt to specificities
Specific asset classes, such as green bonds, social
bonds, asset-backed securities and sovereigndebt, may require dedicated engagement
strategies. These engagements have a specificfocus on ESG topics relevant to the asset classand aim to foster better practices or disclosures.
Amundi participates in general meetings forbonds when requested by the fund managers.
Subsequently, we engage on ESG issues at issuer
level, when investment professionals, apart fromtheir holistic ESG-related active dialogues withissuers, engage also the issuers on ESG subjects
that have financial materiality for the value ofthe instrument they are invested into.
In addition, Amundi’s engagement spans acrossdifferent continents and takes into accountlocal realities. The aim is to keep an equal levelof ambition globally while taking into accountregional realities.

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Asset class-based engagement – Supporting
Emerging Markets to speed up ESG integrationand disclosure
It is a conviction of Amundi’s Emerging Markets(EM) team that engagement can drive valueenhancement in a mutually beneficial way.

October 2022

Apart from the different engagement streams
that could trigger dialogues with issuers fromemerging markets, the ESG Research team,
EM fund managers and financial analysts havetogether built a specific engagement stream for
Emerging Markets.

➜ Our progress in 2021
Actions
Building upon our work in 2020, the specific Emerging Markets Engagement campaign on ESG
issues has increased in scale and scope, in 2021.
Amundi initiated conversations with 107 companies (compared to roughly 80 the year prior)across Central and Eastern Europe, Middle East, Africa, Latin America and Emerging Asia.
In 2021, the majority of engagements have been bottom up in nature, focusing on company
specific material issues identified with Amundi’s proprietary ESG rating tool. A wider rangeof ESG topics were included in the questionnaires, including but not limited to sector specifictopics such as green chemicals, sustainable construction, and responsible forest management.

Outcomes
In 2021, we noted an increased interest from EM issuers that strived to better understandthe concept of ESG materiality and its importance to investors, from both a risk and an
opportunities perspective.
While ESG is not as advanced in EM as in Developed Markets (DM), it is rapidly catching up.
We believe there is sizeable value to be captured through engagement and it is critical that, asthese markets grow, issuers within these markets not only grow at a similar or faster pace but
also responsibly, creating value for both their shareholders as well as associated stakeholders.

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Case study 9: ENN Natural Gas: a fast ESG improver thanks to dedicatedengagement:
Context
Amundi observed that ENN Natural Gas, a China-based company, was lagging on several
E, S and G criteria, like GHG emissions, Health & Safety, and various Corporate Governanceconcerns. Amundi conducted an engagement process consisting first in understanding where
the issuer was headed and what changes could be expected on each respective front, if any.
On emissions, we noted that the issuer plans to revise its reduction targets in line with climate
science. For Health & Safety (H&S), we noted the company’s plans to expand certifications tomore member companies, but not all.
Actions
While acknowledging progress, Amundi wished to push further the company in their actions,by providing them concrete recommendations of improvement related to:– the disclosure of the methodology used for their emissions reduction targets,– the expansion of targets’ scope to scope 3, including but not limited to consumer end
usage,– the assessment and disclosure of climate related risks and opportunities (TCFD framework),– the integration of climate related KPIs in executive remuneration,– the certification of 100% of company sites to an international H&S standard– the set-up of a business ethics trainings for all suppliers and contractors as early as
possible.
Outcome and next steps
Amundi considers that to date the dialogue has been constructive. Amundi continues engaging
with the issuer with the aim to map progress as well as drive further improvements.

Asset class-based engagement – Engaging
with sovereign entities
On the sovereign front, engagement plays animportant part in our portfolio management andallows us to guide these sovereigns on what we
consider a good global standard. Amundi has
been actively approached by various sovereignissuers (especially amongst EM issuers) to seek
our guidance on how they should structure their
ESG framework.
Sovereign engagement occurs most of thetime when an entity is interested in issuing new
bonds, and would like to gather most popularfeatures amongst investors in order to maximize
the demand. Typically, both Amundi investment
team and sovereign ESG analysts participate

in the engagement, covering topics frommacro-economics to increasingly ESG-related
questions such as corruption, deforestation
or indigenous rights, and related to theirsustainability framework, if any.

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Illustration 30: Chile Social Bonds issuance
Amundi participated in one of the small group investor calls organized by the Chilean Ministryof Finance, during which the Ministry of Finance (MoF) explained their Sustainable Bond
Framework and sought recommendation from investors prior the issuance of new social bonds.
Amundi’s focus was related to sustainability dimensions on deforestation and Indigenous
people’s rights issues. The MoF offered a medium term plan. Taking into account both ourinternal ESG team assessment as well as valuation, we decided to participate in both the 2033
and 2028 bonds.

When a country goes into default and has torestructure its external debt due to its inability tohonor the existing one, the major bondholders
form a group with the solicitor to negotiate
directly with the sovereign what terms andconditions the bond restructuring agreement
should have. The bondholders who hold themost of that country’s debt will have a bigger
weight in the negotiation process. This type ofengagement is much more direct and intensethan when the issuer is issuing new bond. As thecountry is already struggling to meet its debt
payment, negotiation tends to be more difficult

because firstly, the country is usually already in aquite distressed situation and it may be difficult
for the government to concede to bondholders’requests easily. And secondly, bondholders may
have a different agenda, which makes it timeconsuming to agree to common terms.
In any case, Amundi pushed and will continue
to push for bond restructuring to be linked to
relevant KPIs for the underlying countries andto exercise its say as bondholder to promotesustainability-linked issuance.

Illustration 31: Debt restructuring– An example of a successful restructuring linked to sustainable objective is the Belize Blue
Conservation bond. The Nature Conservancy (TNC) and the Government of Belize worked
together on restructuring the entirety of Belize’s external commercial debt. As part of theterms of the transaction, Belize has formally committed to several important conservation
goals, such as protecting approximately 30% of its ocean, including coral reefs, mangrovesand fish spawning sites.
– In the context of the debt restructuring of a recent Latin American sub sovereignissuer, Amundi was one of the 10 bondholders in the discussion. Amundi proposed therestructured bond coupon to be linked to SDG #4 (quality education) or SDG #6 (cleanwater and sanitation) via a Sustainability-linked bond format. Although the proposal was
not included in last year’s restructuring, our proposal had nonetheless raised the keeninterest from the sub sovereign to issue a SDG-linked bond in the future. Amundi will remain
attentive to such a development.

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Assetclass-based
engagement–
Supporting Green bonds to make theenergy transition concrete

October 2022

Our engagement activity relating to that asset
class was focused on the improvement ofreporting capabilities.

Amundi believes that the green bonds asset
class has the potential to channel private capital
towards energy-transition financing needs.

➜ Our progress in 2021
Illustration 32: Improving reporting practices

Context
In 2021, 20 green bond issuers have been engaged to improve impact reporting. Morespecifically, Amundi engaged with issuers on two key priorities related to impact reporting:
1. the adoption of the International Capital Market Association (ICMA) Harmonized Framework
for Impact Reporting
2. the adoption of Life Cycle Assessments, to calculate Environmental Impact
Amundi observed that for certain sectors, adopting the Harmonized Framework for Impact
Reporting or even life cycle assessment is not yet a prevalent market practice, due to reasons
related to data availability. Based on this observation, Amundi made this a key topic forengagement.

Actions
We picked 20 issuers, equally split between developing and developed markets, and spread
across a variety of sectors. Through engagement, almost all issuers have shared the difficulties
to collect, harmonize and report the relevant climate impacts and metrics when projects covera wide variety of categories.

Outcomes
In the context of the engagement campaign, Amundi witnesses that some issuers have taken
steps to ensure alignment with the Harmonized Framework for Impact Reporting. Others haveallocated resources allocation.

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Stronger adoption

Companies’ Adoption of the ICMA's Harmonized Framework for Impact Reportingand LCAs Need To Be Stronger

3
2,5
2
1,5

Weaker adoption

78

1
0,5
0

Automobile

Banks

Real Estate

Renewable Transportation Utilities

Harmonized framework for impact reporting

LCA for impact reporting

Source: Amundi Asset Management

The same sample of issuers has been engaged on their adoption of life cycle assessments (LCA),
as a method to calculate the environmental impact in a way to would capture particularly thescope 3 emissions across the value chain (upstream to downstream).
The outcome appears to be quite sector dependent. The level of adoption in the automobile
sector is considered quite mature in terms of carrying out LCA approach on impact reporting(as well as on the adoption of the harmonized framework). For other less manufacturingdependent sectors such as utilities, the study and adoption of LCA in impact reporting arerather scattered. Some issuers cite data availability issues, hindering successful adoption of
LCA reporting.

Next Steps
Going forward Amundi will encourage these issuers to go beyond the adoption of the core
indicators in the Harmonized Framework to spur more comprehensive disclosure. For LCA
impact reporting, we understand the complexities, but we encourage issuers to seek out
external expertise to better carry out LCAs across the value chain.

79 Stewardship Report 2021

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Transition towards a low
carbon economy

24%
3. The 2021
Campaign______________________Natural Capital preservation

Social cohesion throughdirect ans indirect employees
protection

44%

7%
Product, client, societal
2021 Key Figures
responsibility
Strong governance for10%sustainable
development
Number of issuers engaged
in 2021according to Amundi’s engagement themes

3%

Dialogue to foster a stronger
voting exercise and a sounderWe performed 2,334 engagement
actions with 1,364 different companies, broken down
corporate governance12%

as follows:

2021 Engagement broken down by topic

Transition towards a low carbon economy

24%

Natural Capital preservation

44%

Social cohesion through direct ans indirect employees
protection

7%

Product, client, societal responsibility

10%
12%

Strong governance for sustainable development

3%

Dialogue to foster a stronger voting exercise and asounder corporate governance

Geographic Breakdown of Engagements: conducted by the ESG Research Team,
Corporate Governance Team, and total (in number of companies)

500
450
400
350
300
250
200
150
100
50
0
Total

ESG
Team

Pre
AGM

Developed Asia

Total

ESG
Team

Pre
AGM

Emerging Markets

Total

ESG
Pre
Team AGM
Europe

Total

ESG
Team

Pre
AGM

North America

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Illustrations and progress operated in 2021
1. Transition towards a low carbon economy➜ Our progress in 2021
Speeding up the coal exit according to our responsible investment policy
Amundi is keeping-on its transition away from thermal coal, which will lead to a significant
reduction in financial support for companies operating coal assets without strong phase outplans in the next few years. Our philosophy is that companies need to contribute to the low
carbon economy by shutting down (not selling) coal assets and converting to green energy
while taking into account the need for a just transition. To speed up the withdrawal fromthermal coal assets according to the 2030/2040 schedule for respectively OECD/ Rest of theworld, 100% of companies under investment that have thermal coal exposure and no public
coal phase out plans have been reached to share our thermal coal phase out policy. Replies
and publically announced coal exits are tracked to create a database. This database will enable
us to monitor our coal exposure in years to come and to identify candidates for escalation.

Status of Phase-Out Plans for Issuers with Coal Exposure21OECD

Non OECDOECD aligned with 2030
Coal Exit Timeline

Non OECD aligned with 2040
Coal Exit Timeline

OECD Not alignedwith 2030 Exit Timeline

Non OECD Not alignedwith 2040 Exit Timeline

Source: Amundi Asset Management

We consider this 2021 email campaign as the first step in engaging with all companies exposedto thermal coal. Amundi has already undergone direct dialogue with many companies flagged
for coal exposure (by the ESG Research team, investment teams, or a combination of the two).
Our internal database helps us holistically track companies where progress is too slow andfurther active engagement is required.

21. Amundi engaged with all issuers flagged as having thermal coal exposure according do our data providers MSCI and
Trucost81

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Case study 10: Driving momentum through engagement with RWEContext
Amundi has committed to phase out thermal coal from its investments by 2030 in the European
Union and OECD countries and in 2040 in non-OECD countries. Despite RWE’s progress since
the beginning of their decarbonisation journey, prior to 2021, RWE phase out was not planned
to be fully implemented before 2038.

ActionOn Amundi’s side, we have conducted a fair share of engagement with RWE regarding theirdecarbonisation plans and coal phase out (both on coal generation and thermal coal mining),
nudging them to decarbonise according to the pathway set by the Paris Agreement. Our
engagement effort has progressively intensified since 2020, as their 2038 target for phase-out
was incompatible with the 2030 required timeline. In addition to this active dialogue focusedon their coal phase out plan and climate strategy, Amundi brought the topic to their 2021 AGM,
by asking them a related question, as part of an escalation process.

Outcomes, issuer's dynamic & perspective
Since November 2021, we have observed that RWE is positive about the recent government
announcement to phase out coal by 2030 and we believe that continuous engagement on
thermal coal played a role in that.
Indeed, RWE is now open to an accelerated coal exit, in line with the coalition treaty ofGermany’s new Government. However, the coalition partners are convinced that a necessary
pre-requisite is a massive growth of renewables and networks as well as a sizeable build out
of firm capacity like hydrogen-ready gas-fired power plants, to ensure security of supply. RWE
supports this logic and contributes to it with investments of EUR 15 billion in Germany by2030. RWE has also actively increased the likelihood of an early coal exit and while a numberof strategic components still need to be figured out, this is a major step in the right direction.
While this faster momentum is largely due to the German government, the investor community
engagement played a role. This case shows the importance of aligning stakeholders action toaccelerate the energy transition.
Amundi will continue to engage with RWE to promote a successful 2030 exit.

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Case study 11: Phasing out from Thermal Coal: A Crucial Role for the Insurance
SectorBuilding upon its work in 2020, Amundi’s engagement with insurers on their coal policies
continued during 2021. The insurance industry carries an important responsibility to thecontribution of reducing climate change impact. The sector can significantly support theenergy transition through its investment portfolios as well as its underwriting policies. At thesame time, climate change also forms a risk for the industry as it led to increasingly frequentand severe weather events around the globe, such as floods, droughts, wildfires and storms,
which impact the claims that insurers are to carry.
Burning coal remains the single biggest source of CO2 emissions. The NZE (Net Zero Emissions)scenario presented by the International Energy Agency (IEA) in its recent Net Zero by 2050
report leaves no room for new unabated coal plants approved for development, new coal minesor mine extensions after 2021. It also stipulates there needs to be a phase-out of unabated coalin advanced economies by 2030 and in the rest of the world by 2040.

ActionAmundi has initiated an annual dialogue with insurers on their coal exit strategies to demanda coal phase out by 2030 in OECD and EU countries and by 2040 for the rest of the world.

Outcomes, issuer's dynamic & perspective
Over 2021, we saw greater momentum than the prior year. Two thirds of our sample ofcompanies announced a reinforcement of their coal policy during the year.
We observed that most insurers have difficulty or are hesitant to commit to a full phase out
plan for thermal coal in line with a 1.5°C scenario (by 2030 for the OECD countries and by 2040
for the rest of the world). Some of the Asian insurers appeared unwilling to move faster thantheir country policies. Some insurers also mentioned that a lack of data was preventing themfrom tightening their policy (to exclude coal developers, or to introduce an absolute threshold).

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All Companies but three have improved their Coal Exit Strategy in 2021:
Company

Achievements during 2021

Insurer A(US)

Still no announcement of a policy.

Insurer B(Japan)A reservation on the policy has been
removed.

ChangeDemands for next steps=

Formally publish a coal exit policy.
Exclusion of new coalmines andmine extensions.
Exclusion of coal developers.
Adopt an exit policy for existing coalplants and coalmines.
Define a full phase out plan.

Insurer C(Japan)Policy has been extended from coal
power projects to now also include coalmining projects.

Extend the policy to all coal-relatedcompanies and infrastructures (fromprojects only).

Some exceptions have been eliminated.

Exclusion of coal developers.
Adopt an exit policy for existing coalplants and coalmines.
Define a full phase out plan.

Insurer D(UK)

Introduction of an absolute
threshold.

First announcement of a policy.

Exclusion of coal developers.
Define a full phase out plan.
Extend the coal policy to its third
party assets.
Insurer E(Hong Kong)First announcement of a policy.

Insurer F(US)No evolution of policy.

Exclusion of coal developers.
Extend the coal policy to its third
party assets.

=

Introduction of an absolute
threshold.
Exclusion of coal developers.
Define a full phase out plan.

Insurer G(the Netherlands)

Finalize coal exit strategy

Tightening of the relative exclusion
threshold for coal-fired power plants
Divestment and exclusion of coaldevelopers.
Exit strategy for coal related
investments, to be finalized over2022-2024.

Insurer H(Italy)Tightening of relative and absolute
thresholds for coal mining and coalfired power plants.

Remove the exception for heavily
coal-dependent countries (doubts
remain on full phase out attainability
for these issuers).

Introduction of an absolute thresholdfor coal developers.

Extend the coal policy to its third
party assets.

Commitment to full phase out forinvestments and underwriting.
No new property cover underwriting.
Insurer I(Germany)

No evolution of policy.

Source: Amundi Asset Management=

Advance the phase out from coal forOECD from 2040 to 2030.
Extend the coal policy to the treaty
reinsurance business.

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2. Natural capital preservation (ecosystem protection & fight against
biodiversity loss)
Case study 12: Plastic engagement - Year 3
Context
Plastic pollution is a key environmental issue. Plastic currently constitutes 85% of all marine
litter and the amount of plastic in the oceans and waterways could more than double by 2030
and triple by 204022.

ActionIn 2019, Amundi ESG Research team launched a plastic engagement campaign with the aim
to open a dialogue with sectors where plastic is a material issue, namely: household personal
products, automotive components, and healthcare.

Outcomes, issuer's dynamic & perspective
After 3 years of consistent engagement, Amundi’s conclusion is that work still needs to bedone to ignite better practices adoption. For this reason, Amundi will continue its engagementon plastic. We understand that some of our recommendations can take time to implement but
we believe that engagement might accelerate the momentum.
In 2022, Amundi has decided to launch a new campaign. It covers the 3 sectors alreadyaddressed by the former campaign and includes follow-up targets (see table hereafter for thetargets detailed by sector), but the scope is also extended to new sectors (Chemicals from the
supply chain and Food that has high exposure to plastic).
SectorHousehold
Personal
Products

2019
Recommendations
More granular
reporting on plastic
exposure including
by product type,product category andgeography
More reporting on
direct negative
impacts/externalities ofcompany plastic in highrisk regions

Healthcare

Shape a strategy onplastic
Improve plastic
reportingCurrent Status

virgin plastic usage by strengthening
plastic recycled content goal.
Targets to reduce plastic by 2030 (suchas increase in % recycled content or %reduction of overall use of virgin plastic)

Going Forward
Improvements in plastic reporting
still needed such as increased
disclosure on single-use packaging(as well as breakdown by otherproduct type), and geographic
reporting especially for high risk
geographies

Evidence of mid-term 2025 targets onplastic
Companies involvement in collaborative
initiatives such as Ellen MacArthur
foundation

possible to reduce packaging by volume,
increasing recyclability and using
renewable materials (such as recycled or
bio-based plastic).

Companies still need to become
more quantitative in theirreporting, both in terms of metrics,
KPIs and targets.

Greater focus on eco-design in R&D
process, aimed at reducing hazardous
substance such as phthalates or PVC or on
making the product easier to recycle after
its use.

Automobile
Components& Tyres

Improve transparency
and reporting including
plastic exposure andenvironmental impacts

unintentionally released microplastics withthe aim to reduce them.

Companies should be moretransparent and disclose dedicated
KPIs such as the amount of plastic
reduced during the year.

suppliers on plastic reduction

Source: Amundi Asset Management

22. https://www.breakfreefromplastic.org/wp-content/uploads/2021/10/BRAND-AUDIT-REPORT-2021.pdf

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➜ Our progress in 2021
Illustration 33: Launch of an engagement campaign on biodiversity

Context
The UN Intergovernmental Science-Policy Platform on Biodiversity and Ecosystem Services(IPBES) provides evidence that the so-called Holocene extinction is unprecedented and is a
result of human activity. Biodiversity loss has accelerated rapidly over the last 60+ years acrossall regions of the globe23.
While biodiversity loss represents multiple risks, companies are not addressing their impact at
a quick enough pace. This can be explained by the complexities of measuring biodiversity andthe fact that many of the key frameworks to guide disclosure are still in development. However,
we believe that companies must start acting now to preserve biodiversity. For this reason,
Amundi launched a formal engagement campaign around biodiversity in 2021. Based on theoutcome of our engagement efforts in 2020 with 96 companies - mentioned in the previous
report-, we concluded that, across the sectors, issuers had a low level of maturity of practices
and that a common framework and guidelines were required in order for a company to makeprogress.

ActionAmundi decided to address the lack of maturity on this issue by engaging a smaller numberof companies, in order to be able to push sector specific best practices rather than a genericsolution, before re-engaging the previous sample of 96 companies. The aim for this second
year of engagement on biodiversity was therefore not to demand improvements to the 96
previously engaged companies but rather to address a significant gap related to common
framework guidelines.
Amundi therefore directed its engagement effort, in conjunction with its membership to the“Finance for Biodiversity” pledge, into a fundamental work of establishing sector-based bestpractices and recommendations.

23. WWF, Living Planet Report, 2020.

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Amundi reached out to over 67 companies and conducted 56 engagement calls on biodiversity.
Our engagement campaign covered 8 different sectors divided into four macro categories.

Engagement with 56 companies, across 8 sectors and 18 countries
Sectors with Indirect Exposure(Financial) to biodiversity

Utilities

Insurance
Sectors with Primarily Direct
Impacts on Biodiversity
Food & Food Retail
Food Based Sectors withPrimarily Upstream andDownstream Scope 3 impacts

Mining & Metals

Consumer Services(restaurants & catering)

Paper & Forest
Products

Pharmaceuticals

Sectors with Biodiversity
Exposure Acrossthe Value Chain

Chemicals

Source: Amundi Asset Management

56 Engagements in 18 countries

Source: Amundi Asset Management

Outcomes, issuer's dynamic & perspective
Amundi aims to improve common knowledge of biodiversity-related issues among issuers aswell as within the finance industry. In line with this objective, we published a Thematic Paperon the topic for issuers to refer to in Q4 2022 in an attempt to improve best practices, as we
did for “Circular Economy”.

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Case study 13: Biodiversity in Restaurant & Catering sector
Context
The food industry is frequently mentioned as the sector primarily driving biodiversity loss
globally24. While the industry is responsible for severe biodiversity loss25, it is also heavily
dependent on biodiversity and faces significant risks associated with its depletion. The foodsector impacts on biodiversity are often indirect, primarily caused by the sourcing of raw
materials. This makes the topic difficult to measure and manage, partly because of the scaleof global supply chains. The restaurant and catering sub sector has an additional layer ofcomplexity as there is a high degree of independence among various operations, geographies,
branches, and stores with sourcing decisions often made at a country or regional level.

ActionRegarding the matter of biodiversity in the restaurant & catering sector, Amundi’s demands
are as follows :1. Strategy from the top: extent to which biodiversity is a specific subject at the board leveland degree to which the company has formalized its biodiversity strategy
2. Identification and management of Impacts, Risks, Dependencies, and Opportunities:
extent to which the company has identified and is managing biodiversity linked impacts, risks,
dependencies and opportunities
3. Metrics, Targets, and Reporting: how a company is currently measuring and assessing
biodiversity risks and impacts and the extent to which the company is working collectively
with peers and its ecosystem to address reporting difficulties
In the specific case of engaging with a company in the Restaurant & Catering Sector, thefirst priority was to map the company’s supply chains to support both their climate andbiodiversity related goals. Indeed, although sourcing decisions are made locally, the global
policy is translated at the local level (and then re-aggregated for top down reporting). We
consider that the company can begin making sourcing commitments at a more local levelwith accompanying indicators to help measure the progress towards their wider goals. We
understand that the complexity of the business means that the change must start with a few
key commodities and impact drivers (i.e. soy, seafood, food waste, plastic, etc.) and that eachcommodity needs its own approach. This is a very common approach for the sector and while
an important first step, it could mean that some commodities or impacts remain unaddressed.
Like many companies in this engagement, we urge the company to do the exercise of assessing
how they impact biodiversity more holistically so they can begin to understand (and manage)these other impacts.

Outcomes, issuer's dynamic & perspective
Amundi’s dialogue with the company is at initial stage, which means that it is too early toconfirm improvements. Despite the challenges inherent to addressing biodiversity loss, thecompany already demonstrated strong awareness of the topic and is actively working on
related issues.

24. https://www.unep.org/news-and-stories/press-release/our-global-food-system-primary-driver-biodiversity-loss
25. The Encore Tool identified Consumer Staples as having “very high materiality rating” for terrestrial ecosystem use,water use, freshwater ecosystem use, marine Ecosystem use and “high materiality rating” for GHG emissions, non-GHG air
pollutants, water pollutants, soil pollutants, solid waste, and other disturbances
https://encore.naturalcapital.finance/en/explore?tab=impacts

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The company acknowledges the rise in demand from their customers for vegetarian and plantbased options worldwide. To support its commitment to propose 33% plant-based dishes intheir menus by 2025, the company has launched the Future Food Collective, a collaborative
research initiative bringing its chefs together with industry experts and key suppliers toreshape consumption habits. More interestingly, they have identified a business opportunity
related to their activity of catering services. To support their clients in their own climate andenvironmental commitments, they can position their catering services as a way to help theirclients achieve their own climate targets. While for the moment they mainly see the climate
aspects of this proposition, growing awareness around biodiversity loss may allow to extend
this innovative service to support new targets.

3. Social cohesion through the protection of direct & indirect employees,
promotion of human rights
Case study 14: Living Wage engagement on Carrefour
Context
Carrefour is one of the biggest food retailers in the world with more than 12,000 stores and
320,000 employees in 30 countries. With a large employee base, wage related matters area significant issue for the company. While a majority of their operations are in countries thatoffer some degree of worker protections, Carrefour historically had no overarching policy toensure their employees globally received a wage beyond local minimums, sufficient to meetbasic needs.

ActionAlthough Amundi already engaged with Carrefour on a living wage in global supply chainsthrough the Platform Living Wage Financials (PLWF - see Amundi 2020 engagement reportfor reference-), we decided that specific engagement on a living wage for direct employees
was also required.

Outcomes, issuer's dynamic & perspective
Amundi began engaging with Carrefour on this topic in 2019 and saw a successful outcome
in 2021. Indeed, Carrefour has made promising progress by including language related toa living wage into its group wide remuneration policy (covering the 30 markets in which itis active). They namely acknowledge that living wage is a human right recognized by theUnited Nations (UN) and the International Labor Organization (ILO) and state that “wages
must enable employees to meet their basic needs and those of their families and to attain adecent standard of living. These must cover the purchase of goods and services to cover theneeds of food, health, clothing, as well as education and transport”26.

26. https://www.carrefour.com/en/csr/commitment/act-people-remuneration-and-decent-wages-our-employees

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Amundi strongly welcomes this significant progress from Carrefour, which positions them asa standard setter for retailers globally. Nonetheless, going forward, we will remain attentive to
how Carrefour plans to implement and monitor this policy across 30 markets, especially when
the living wage varies per region. An additional positive development is that Carrefour strongly
supports collective bargaining agreements as a means of facilitating social dialogue and has
signed pledges with global unions as well as local collective agreements. We see this as a major
strength in Carrefour’s plan to implement this global living wage policy but still expect to get
more clarity on how Carrefour operations will directly monitor and implement it (especially inmarkets that Carrefour might consider to be higher risk).

Case study 15: Engaging on the Just transition with Volkswagen
Context
The automotive industry is undergoing considerable structural changes due to the rise of
automation and electrification. Because this can have disruptive consequences for employees,
there is a considerable need for strategies focused on a just transition. Volkswagen is no
exception as the company employs more than 660,000 people worldwide and has pledged
to spend EUR33 billion on its electric vehicle (EV) business over the next few years27. A large
portion of the workforce is likely to be impacted by this shift to EVs. Thus, Amundi selected
Volkswagen as part of our initial just transition engagement pool, in order to better understandthe social impacts of their shift to EVs.
Historically, Volkswagen has demonstrated relatively strong employee development programsfor the sector28. As the topic of just transition is still considered an emerging topic, we still see
room to improve transparency regarding how the company will manage this specific transition.

ActionAmundi’s key asks to Volkswagen in 2021 were as follows:– Assessment (reported publically) of the company training needs to successfully manage
a just transition now and in the future, including the share of current employees whose
competencies will become obsolete and the projected number of employees with new skills
that will be needed to support the evolving business.
– More transparency on just transition specific employee training at the company, includinginternal KPIs used to measure the impact and effectiveness of this training.
– More transparency on how the human resources department is managing the just transitioninternally, including the identification of potential redundancy bottlenecks.

27. Volkswagen, 2021
28. In 2020, Volkswagen reported that there will be no major redundancies planned until 2029 and most of the job
reductions will be through retirements. They also reached an agreement in 2016 between Volkswagen’s union andthe board of management on the company’s future strategy to transition in a “socially compatible way” https://www.
volkswagen-newsroom.com/en/press-releases/volkswagen-concludes-pact-for-greater-economic-viability-and-a-moresecure-future-1653

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Outcomes, issuer's dynamic & perspective
We have witnessed some positive developments. For example, Volkswagen has reported thatroughly 50% of their employees continue to perform manual jobs in production and that thecurrent structure of the workforce does not reflect expected changes to their employment
needs including a surplus of staff in certain manual areas and an increased demand for techprofessionals. They are working with an academic institution to have a clearer picture of theareas where job cuts will occur and those where further qualifications are needed (in particular
digitalization and electrification). Furthermore, Volkswagen has specified that future employee
training will focus on important future technologies.
While we welcome these developments, we are aware that the company is still in the process offully developing its just transition strategy. Amundi will continue to engage with the company
going forward to encourage more transparent reporting on how Volkswagen will manage andreport on its just transition.

Case study 16: Engagement with Top Glove following a controversy related to apotential breach of the UN Global Compact
Context
When a human rights abuse occurs, following the UN Guiding Principles, Amundi works
to ensure that companies carry out effective remediation to those impacted and enhance
processes to prevent repeated occurrences.
In general, we prefer engagement to divestment as we have a greater ability to encourage
positive change when invested in the company. For cases of severe and repeated violations
without proper remediation plan, when engagement fails, we may escalate in order to accelerate
the momentum of the remediation.
Multiple controversies arose regarding poor Covid-19-related work conditions at the Malaysiancompany Top Glove, the leading manufacturer of disposable rubber gloves. Following up froma whistleblowing alert and its mishandling, the company was under investigation over the massoutbreak of Covid-19 at its facilities.

ActionPoor labour practices and governance issues led Amundi to oppose the election of the entire
Board of Directors at the 2021 Annual General Meeting. We had notified the Company of ourvoting intentions.
An engagement call with Top Glove was arranged on January 21, 2021, to discuss the serious
governance concerns Amundi had and, areas for improvements, such as:– Improvement in workers' accommodation, improved health care and preventing measures,– Introducing helpline to workers and other communication tools,– Election of workers' representatives,– Establishment of a whistleblowing committee.

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Outcomes, issuer's dynamic & perspective
The engagement calls concluded with the mention of immediate measures planned by thecompany. Amundi will remain vigilant to the corrective dynamics of the company’s policies andtheir implementation in the future.

4. Client, product & societal responsibilities
Case study 17: Vodafone, a committed actor willing to further improve thetransparency it provides
Context
Vodafone is one of the largest telecommunicationcompanies operating across many different
geographies. It is the second-highest ranking
telecommunication company in the 2020 Ranking
Digital Rights (RDR) index and notably commits
to protect individual rights across its operations
and activities, including in the development ofalgorithmic systems. Nonetheless, the RDR index
highlighted room to improve transparency oversome of its practices.

ActionThrough a dedicated engagement campaign in 2021, Amundi asked Vodafone to disclose
further outcomes of individual rights due diligence conducted on its existing services, theenforcement of its policies, its algorithms and targeted advertising, as well as zero-rating
programs.

Outcomes, issuer's dynamic & perspective
Vodafone was both receptive and prepared: they informed Amundi that they had recently
carried out two human rights impact assessments on child rights and high-risk markets. In
addition, the company is in the process of integrating human & individual rights further into key
processes such as product design, Artificial Intelligence technologies, but also their enterprisesales process. While engagement with the company in 2021 highlighted several positive
developments, our conclusion was that Vodafone could develop a more systematic approachto human rights controls and risk management, as well as strengthen its efforts on data privacy
and user rights.
As the next step, Amundi will continue to engage with Vodafone with the expectation that it
carries out a comprehensive human rights due diligence, discloses its scope and outcomes andsets relevant objectives for the future.

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Principle 10
Signatories, where necessary, participate in collaborative
engagement to influence issuers.
As a responsible investor with a clear understanding of the role and importance of ESG criteria,
Amundi participates in numerous initiatives as a member and signatory. We are an active
participant in working groups at a range of market bodies – both regulatory and industry-ledorganisations – aimed at moving responsible finance, sustainable development and corporate
governance forward in the interests of our clients.

1. Collaborative engagement: working with our peers
to help drive the conversation
Collective efforts can have a great impact. Just
as we encourage issuers to act collectively on
key sustainability issues, investors also often
collaborate. Collaborative initiatives can provide
additional scale and scope for engagement orprovide opportunities for greater impact.
When deciding between engaging collectively
or on our own, Amundi will choose the mostefficient method to push the agenda, which
could favour a collaborative method. Amundi
may supplement collaborative efforts with direct
engagement if a collaborative engagement
does not cover particular issues, sectors, orcompanies, or if the collaborative initiative does
not address the topic in a way Amundi mightwish. Amundi values both engagement types asa mean to have a positive impact on sustainableoutcomes.
Amundi usually plays an active role incollaborative initiatives. Amundi generally takes
the role of lead investor on engagement with
one or more companies. Sometimes an ‘active
role’ also means that that Amundi contributes
to the planning, methodology and operations of
the initiative.

By contrast, on some occasions, Amundi issimply a participant in a collective initiative. This
is often the case when the initiative is dynamic
and impactful without particular assistance from
Amundi. For other collective actions, Amundi
might contribute to the thought leadershipon emerging topics or provides contacts andresources. As a participant, Amundi has theopportunity to gain insights into new andemerging problems or advise the group on
the feasibility of proposed methodologies toprepare for eventual active engagement.
International initiatives include institutional
investors and asset management professionals.
Their goal is to encourage businesses to improvetheir practices and transparency in terms of
combatting climate change and deforestation,
protecting water resources, health, nutrition indeveloping countries, and so on. We actively
participate in the development of standards andinitiatives where we believe the additional effort
will be important to client outcomes, and lend
our weight to other initiatives where we feel thisis the most positive contribution we can make.

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2. Collaborative engagement: involvement of Amundi
in industry bodies
Industry bodies on which Amundi staff member hold formal roles
Initiative

Topic

PurposeAmundi's involvement

FIR (Forum pourl'Investissement
Responsable)

Responsible
finance

The FIR seeks Socially
Responsible Investment(SRI), to ensure that moreinvestments integrate theissues of social cohesion andsustainable development.
With other SIFs (Sustainable
Investment Forum), the French
SIF is a founding member of theEuropean network, Eurosif.

• FIR- AG CAC 40: Active
participation in drafting ESG
questions at CAC40 companies’
AGMs

Professional body

• Amundi co-headed the working
group that led to the publicationof guidelines to asset managementcompanies for setting a fossil fuelpolicy for the oil & gas sector

Association Française dela Gestion financière

Responsible
finance

Chair of the engagement
commission• Working group on gender diversityand disability
ICMA - International
Capital Market
Association

Environnement
and social(Green Bonds Principles,
Social Bonds Principles
and Sustainability-Linked
Bond Principles)

Finance for Tomorrow

Responsible
finance

ICMA brings together members
from all segments of thewholesale and retail debt
securities market and focuses
on a comprehensive rangeof regulatory and market
practice issues which impact all
aspects of international market
functioning.

• Member of executive Committee(Green Bonds and Social Bonds)

Finance for Tomorrow,an initiative led by Paris
EUROPLACE aims to promotesustainable finance in France
and internationally.

• Founding member• Member of Working Group (SLBs)• Leader of the Impact Measurement
WG for Social Bonds in 2020-2021
season• Active membership andcontributor to "Taxonomy andEuropean Green Deal"; "Just
Transition" and "Green Bonds"
Working Groups• Investors for a Just Transition
coalition (Lead on Transport
Working Group; Participation in
Building & Construction Working
Group) – Member of the biodiversity
working group as well.

WDI - Workforce
Disclosure Initiative Letter

Corporate
workforce
disclosureThis urges companies todisclose better and morecomparable data on theiremployees and supply chains,and shows the intention ofAmundi to integrate workforce
issues into its investment
decisions.

• Drafting and sending letters tocompanies complete the WDI survey• Member of advisory committee in2021

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Access to Medicine Index

Access to
Medicine

This initiative identifies accessto medicine best practice (inpricing, licensing and R&D for
instance).

• Co-lead investor for theengagement of a pharmaceuticalcompany

PLWF - Platform for
Living Wage Financials

Living Wage

The PLWF aims to address thenon-payment of living wage
in global supply chains in thegarment industry, retail/foodretail, and food.

• Active Member of Garment &footwear WG: active engagement(lead on multiple company
engagements), jointly presented
our findings about Covid19/Living
Wage at the 2021 OECD Garment &Footwear Forum• Participant in Food & Agri WG –jointly sent AGM questions to two
food retail companies on the topic
of living wage

La Fondation de la Mer

Biodiversity /Pollution

The Fondation de la Mer
contributes to the research andprotection of the Oceans.

• Steering Committee Participant
for the Ocean Framework (a tool
helping companies to identify
and improve the impact of theinteractions with the oceans.

The 30% Club France
Investor Group

Genderdiversity

Six asset managers, including
Amundi, call on French large
caps to establish action plan
to have at least 30% women in
executive management teams
by 2025.

• Founding member• Co-chair for 2021 engagement
season• Active engagement withcompanies (lead on multiple
engagements and participant inmost other engagements)

Further industry organisations in which Amundi is involved
Initiative

Topic

PurposeAmundi's involvement

IIGCC - Institutional
Investors Group on
Climate Change

ClimatechangeThe IIGCC mobilizes capital forthe low carbon transition and toensure resilience to the impacts
of a changing climate.

• Amundi signed the IIGCC’s Investor
Expectations for the banking
sector to take into consideration
the banking sector's critical rolein aligning the real economy withthe goal of net zero emissions by
2050 and in limiting warming to 1.5
degrees (reduce the financing offossil fuels and increase funding of
low carbon solutions).
• Amundi provided feedback in the
consultation phase for the Net Zero
Standard for Oil and Gas publishedin September 2021, notably on theneed to have more transparency andenhanced granularity on corporate
capex budgets to test their level ofalignment with net zero scenarios

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AIGCC (Asia Investor
Group On Climate
Change)ClimateChangeThe Asia Investor Group on
Climate Change (AIGCC), a
subsidiary of the IGCC is an
initiative to create awarenessand encourage action among
Asia’s asset owners andfinancial institutions about
the risks and opportunities
associated with climate change
and low carbon investing.

• Participation in the Utilities
Engagement program

CDP - Ex Carbon
Disclosure Project

Climate /Forest / Water

CDP runs the global disclosuresystem for companies, cities,
states and regions to manage
their environmental impacts.

• Active member of the CDP Water
Disclosure Project and of the CDPNon-Disclosure Campaign (Climate,
Water, Forest) in which Amundi
engages with companies that have
not responded to CDP requests.
• Participant to the CDP’s Science
Based target campaign• Active discussions about
CDP Forest data use and thedevelopment of biodiversity
information

Climate Action 100+

FAIRR - Farm Animal
Investment Risk & Return

ClimatechangeEnvironment

Launched in December 2017 at
the One Planet Summit. Thisinitiative seeks to ensure thatthe world’s largest corporate
greenhouse gas emitters takenecessary action on climatechange.

• Active membership

A global network of investors
addressing ESG issues inprotein supply chains.

• Lead on specific companies’
engagements• Lead on company engagement
on different sectors (Construction
materials; Airlines)• Contribution to working groupin FAIRR’s Sustainable Proteins
Engagement in which 25 global food
manufacturers are asked to disclose
information on their intention andlong-term approach to transitioning
proteins portfolios towards lower
impact and more sustainablesources in line with the 1.5°C world
Investor Action on AMR
initiative

Antimicrobial
resistance

A collaboration between the
FAIRR Initiative, the Accessto Medicine Foundation, thePrinciples for Responsible
Investment, and the UK
Government to galvanize
investor efforts to address
global antimicrobial resistance.

• Active engagement withcompanies and data providers

World Benchmarking
Alliance

Responsible
finance

The World Benchmarking
Alliance (WBA) seeks tochange the way that business
impact is measured to boost
motivation and stimulate action
for a sustainable future.

• Participation to working groups(definition of Just Transitionassessment framework)

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Finance for Biodiversity
PledgeOctober 2022

Biodiversity

84 financial institutions fromaround the globe signed the
Finance for Biodiversity Pledge.
They commit to protect andrestore biodiversity throughtheir finance activities andinvestments.

• Amundi is an active member of theinitiative and participate in its threeworking groups (Engagement withcompanies; Impact assessment• Public policy advocacy) – Amundi
represented the signatories with aspeech at the High Level Segmentof the Fifteenth United Nations
Conference on Biodiversity (COP15)
to call on global leaders to protect
and restore biodiversity

RHSF - Ressources
Humaines Sans Frontières

Human rights

Initiative to address thecomplexity of forced labor.

• Active role in determining
standards and KPIs that could be
used by the financial industry

France Invest - ESG
Commission

Responsible
finance

Support private markets players
in taking ESG issues into
account.

• Amundi participated in the updateof the Recommendation to facilitate
the dialogue between private equity
and debt issuers and investors.

Human Technology
Foundation

Societal
impacts oftechnology

Collaboration to better
understand the societal impactsof technology.

• Working group to better
understand the societal impacts oftechnology

ICCR - Human Rights in
ICT sector

Human rights

Initiative to urge companies touphold human rights in online
environment.

• Amundi led the engagement with
two ICT actors

ASCOR - Assessing
Sovereign Climate-related
Opportunities and Risks

ClimatechangeCoalition of investors seeking toassess sovereign debt issuers
and their actions on climatechange• Amundi contributed to preparation
works and now co-chairs two of
the working groups on policies andfunding needs for climate change
mitigation and adaptation

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3. Illustrations of collective actions in which Amundi
has been involved
a. Collaborative work with regulators
Illustration 34: 2 examples of collaboration with regulators
European Financial Reporting Advisory Group lab task force
Amundi was part of the Project Task Force on Reporting of Non-Financial Risks andOpportunities and Linkage to the Business Model, that began its work in September 2020and ended in October 2021. The PTF-RNFRO was asked to review the current state of playand identify good practices in the reporting of non-financial risks and opportunities and theirlinkage to the business model.

ICMA29 - Green, Social, and Sustainability-Linked Bonds Principles
Amundi is an Executive Committee member since 2017 and consequently plays an active roleaddressing matters relating to the Principles e.g. the development of Green Bonds market, thestandardization and impact reporting practices. Until June 2021, Amundi was also leading theSocial Bond working group. Amundi is member of the Sustainability-Linked Bonds working
group, Social Bonds working group. Amundi is also member of other groups from ICMA: Impact
Reporting working group, Climate Transition Finance working group, Sustainable/ESG IndicesWorking Group, Advisory and dialogue with other markets Working Groupb. Collaborative work on Climate
Case study 18: Amundi's action with Climate Action 100+
ActionAmundi is an active member of Climate Action 100+, an investor led initiative to ensure theworld's largest corporate greenhouse gas emitters take necessary action on climate change.
In 2021, Amundi supported CA100+ in a collaborative engagement with seven corporates fromvarious sectors and regions: two Japanese companies (capital goods, automotive), three oil& gas companies (France, Brazil, Mexico), a US construction materials company, and a French
airline company

Outcome, Issuer’s dynamic and perspective
Companies results to our Climate Action 100+ are mixed

29. International Capital Markets Association

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Japanese Automotive manufacturer
In our 2020 engagement report, we had expressed concerns on the climate lobbying practicesof the Japanese automotive manufacturer. We noted some positive developments in 2021:
after stating that it would re-evaluate its climate lobbying practices, the company provided
its official support to the newly proposed CO2 standards and electric vehicles goals in the US(while advocating for fair incentives), and released its first climate lobbying report.

US Construction Materials Company
Unfortunately, we saw a lack of progress with the US based construction company underengagement. The company is also cited as a climate laggard in the CA100+ Net-Zero Company
Benchmark. Thus, we decided to escalate by voting down all but one item at its 2021 AGM.

Mexican oil & gas company
In 2021, we conducted an assessment of its new carbon/methane reduction targets based on
its new business plan to support the engagement by CA100+ lead investors. A call will be set
up to give an opportunity to share concerns over the carbon reduction targets that appear
unchanged from the previous plan.

French Oil & Gas Company
Amundi supported a CA100+-led statement
by investors at the 2021 AGM of a French Oil &Gas company. While we supported the climate
strategy of the company by voting positively
to its welcome “Say on Climate” resolution, we
believe the strategy needs to be improve. We
would specifically welcome enhanced disclosure,allowing investors to better understand how thecompany’s climate strategy contributes to andaligns with global net zero goals. For instance,
we advocate for enhanced disclosure, by region,of scope 3 emissions. Emission pathways cansignificantly differ by region in climate change
mitigation scenarios. Providing further granularity
on scope 3 emissions would therefore help
investors to judge more precisely the level ofalignment of the company’s scope 3 reduction
targets with net zero scenarios. We believe there
is no one-size-fits-all reduction target.

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c. Collaborative work promoting best reporting practices
Amundi frequently collaborates with think tank or NGOs on specific topics in order to promote bestpractices.

➜ Our progress in 2021
Promoting greater corporate reporting on Ocean impacts and SDG 14, with “Fondation de laMer”

Natural capital preservation (ecosystem protection & fight against biodiversity loss)

Illustration 35: Examples of work promoting best practices
ActionIn 2019, Amundi started a close collaboration with the Fondation de la Mer (FDLM). The FDLM
is a French Non-Governmental Organisation (NGO) that works with civil society to help protect
marine ecosystems. The FDLM wanted to develop a reporting framework in collaboration with
the French Ministry for the Ecological and Inclusive Transition based on the goals of SDG 14(Life Below Water) to help corporates better assess their impact on the ocean.
In 2021, Amundi worked with the Fondation de la Mer (FDLM) to translate their framework into
an actionable engagement methodology for investors in order to :• To leverage the work of the foundation and duplicate its impact by reaching a larger numberof corporates• To accelerate awareness of the need to manage corporates’ negative impact on oceans.
In 2021 Amundi launched a multi-year engagement campaign on oceans in order to test theframework with 9 companies for the first year. The tool is the first of its kind, easy to use, andhas been developed by experts and tested by companies. There were two specific aims to ourocean engagement:
1. Increase company awareness of ocean impacts and encourage ocean specific ESG policies
and strategies
2. Use the FDLM framework to identify key ocean impact themes

Next steps
Following the 2021 pilot phase, Amundi will double the number of corporates engaged in 2022
and actively participate to the first edition of the One Ocean Summit in February 2022 topromote the FDLM framework30.

30. https://legroupe.amundi.com/article/soutien-l-ocean-framework-avec-la-fondation-de-la-mer

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d. Collaborative work promoting diversity
Social cohesion through the protection of direct & indirect employees, promotion of humanrightsIn France, under the Copé-Zimmermann law,
listed companies are required to have a minimumof 40% of women on the Board of Directors
since 2017. As a natural consequence, gender
diversity was expected to trickle down from theboard to reach all executive management layers.
However, as of mid-2020, women accounted
for 21% on average of the SBF 120 Frenchlisted companies’ Executive Committees. Theirroles were predominantly functional, as only
12% of operational roles in SBF 120 Executive
Committees were held by women.
To address this, the 30% Club France Investor
Group was launched in 2020. It is the Frenchchapter of a global campaign that takes action
to increase gender diversity at board andexecutive management levels31. Amundi helped
to launch the French Investor Group and was cochair of the group in its inaugural engagement
season. The group now has 12 members working
to address the lack of gender diversity in top
management of the companies in the SBF120.

The 30% Club France Investor Group has two
key objectives:
Objective 1: reaching at least 30% of women on
executive committees of SBF 120 companies by
2025
30% is the level at which critical mass is achieved
and contributions from a minority group start
being heard and valued, impacting leadershipdecision dynamics.
Objective 2: specific expectations regarding
disclosure from investee companies
It covers in particular corporate governanceissues, including the process used to identify
suitable candidates for executive management
teams.

Key Highlights from the 30% Club France Investor Group's Annual Activities

Analysis of Current
State of Play• Using public datato assess current
performance of
SBF120 and theirrespective Gender
Diversity Targets

Soft Engagement
Campaign
Active Engagement
Campaign• 14 in person meetings
with corporates toincentivize progress
towards (andbeyond) 30%• 30% Club KPI list
distributed to SBF120
to outline reporting
expectations on
gender diversity

Collaboration with
Friends of the InvestorGroup• Uniting Industry
stakeholders so sharethe same goal
• Knowledge sharing
with Industry Experts

Source: 30% Club Investor Group France

31. The initiative is present with Chapters in Australia, Brazil, Chile, Colombia, Ecuador, Eastern Africa, Hong Kong, Ireland,
Italy, Japan, Malaysia, MENA, Mexico, Poland, Southern Africa, Turkey, UK and the US.

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➜ Our progress in 2021
The group has published a first annual report32 highlighting their 2021 activities.

Context
Key Conclusions of 2021: The SBF120 has a long way to go to achieve gender equality
Amundi analysed the performance of the SBF120 companies to identify candidates forengagement and to track developments to achieve the objective of having at least 30% of
women in executive committee roles by 2025. When comparing data between 2020 and 2021
we observed that the total percentage of women in executive management in France has only
improved from 20% to 23%, demonstrating the need for engagement to encourage fastermomentum towards gender equality.

The Current ‘State of Play’ of the SBF120: to majority of companies are far fromgender equality
100
90% Women ExCom

80
70
60
50
40
30
20
10
0
0

10

20

More women in executive
management versus
women in the company

30

40
50
60
% Women employees

Fewer women in executive
management versus
women in the company

70

80

90

100

Parity: equal % of women
represented in top mangement
and in the company overall

Source: 30% Club Investor Group France

ActionAmundi conducted 14 in person meetings with corporates with additional conversations
occurring through email. Through our dialogue with French companies, we observed that
sectors with high rates of female employment (Financials and Consumer) have a clear problem
with glass ceilings. While targets and strategies are set, these sectors have a long way to
go to increase diversity at the highest level of management and, unfortunately, many were
unwilling to have a dialogue with the investor group. By contrast STEM (Science, Technology,
Engineering, and Mathematics) sectors, despite their historically low rates of women, showeda strong willingness to improve as demonstrated by clear commitments (on both getting more
women into the companies and ensuring they reach top management), and a willingness to
speak with the investor group and learn from our insights.

32. https://30percentclub.org/wp-content/uploads/2022/01/30Club_France_Diversity_Report_Final.pdf

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We launched a “soft” engagement campaign, sending our own proprietary KPIs list – 38 KPIs
organized around 11 diversity topics - to the SBF120 companies, in order to outline our reporting
expectations. From the answers we received, we observed that all KPIs are achievable andreported, but there is a lack of consistency in how companies report on quantitative diversity
data. Furthermore, there is a lack of granularity and transparency on key diversity data points.
Lastly, global standards on gender diversity are needed to guarantee employees in different
countries equal benefits and opportunities.
We collaborated with experts and other stakeholders seeking to address the poor rates ofgender diversity. This included the French Business Association MEDEF, that shared theirown data collection efforts. By examining the MEDEF data, the 30% Club France Investor
Group made several observations: a majority of the SBF120 companies have targets on gender
diversity, but only very few aim at parity; there is significant ambiguity regarding the perimeterof these targets; there is a high degree of variability on timelines to reach targets.
The observations provide the 30% Club France Investor Group with a solid foundation to lead
into year 2 of the Investor Group.

Case study 19: Société Générale and the Financial Sector
Context
When considering total workforce, the financial sector presents a very good gender balancewith 50% women on average, better than the 39% women of the total SBF 120 companies.
While we could expect a similarly balanced representation also at the executive managementlevel, such is not the case. Women account for 24% of Executive Committees members, noteven 1% higher than the total SBF 120 average. We believe this represents a lost opportunity
for financial companies, which have had access to a large female talent pool for a long time
already.
At the time the investor group was launched in late 2020, Société Générale had 57% women in
its workforce and only 16% of the executive committee members were women.

ActionAt the end of 2020, Amundi helped launch the 30% Club France Investor Group and became
its co-chair for the inaugural 2020-2021 season. When the Investor Group was launched, theengagement expectations described above were sent out to the entire SBF120 companies. The
Chairman of Société Générale showed great interested in the Investor Group and proposed an
engagement meeting with him in attendance in early 2021.
In particular, the group’s specific demands to Société Générale were as follows:
1. Demonstrate a greater gender balance at the executive committee level (highest governing
body below the board) with more concrete momentum towards their targets and action plansin the near term
2. Disclose clear public action plans on how Société Générale intends to drive gender diversity
at the company all the way up to the highest management levels

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Outcomes, issuer's dynamic & perspective
Société Générale highlighted that diversity & inclusion is a strategic priority for the group. The
group has set a target of having 30% of women in its governing bodies by 2023, and more
precisely in the following committees:• Strategic Committee (Top 30 positions), from 24% women at the end of 2020;• Management Committee (Top 60), from 29% women at the end of 2020;• Key group positions (Top 150), from 21% women at the end of 2020.
The Strategic Committee includes General Management (highest governing body below theboard) which is a body with six members and only one woman. At this particular level, there
remains no gender diversity target. While we were in favour of the overall targets, we insistedon the need to aim at gender balance at the highest management level and stated our wish to
see this reflected in the future.
Despite no target having been set at the general management level, we were delighted to hearlater in 2021 that the newly appointed Deputy General Manager and Chief Operating Officer,
effective from 17 January 2022, was a woman. This change raised the representation of womenin General Management to 33% (2 out of 6).
Going forward in 2022, Amundi will continue to engage with Société Générale to follow up on
the actions they are taking to achieve the targets they have set out as well as how they areassessing the effectiveness of those strategies.

Case study 20: Carrefour – Hurdles in reaching its targets but dedicated actionplans to address the issue
Context
At the end of 2020, Carrefour had 18% women in the Executive Committee and 58% overall. The
company had not yet set hard diversity goals for the Executive Committee level but has put
in place a plan to reach 40% of women in key positions and 35% of the top 200 management
positions by 2025. While women accounted for 31.5% of appointments to key positions in 2019,it was only 23.2% in 2020.
Gender equality does factor into executive compensation. Since 2019, 25% of the long-term
incentive plan and 20% of the annual variable compensation for the Chairman and CEO arebased on the company’s Corporate Social Responsibility (CSR) index. Within the index, two of
the 17 indicators are linked to gender diversity.

ActionEngagement in the context of the 30% Club France Investor Group, of which Amundi is anactive member.
The 30% Club France Investor Group has two key objectives:• reaching at least 30% of women on executive committees of SBF 120 companies by 2025
• specific expectations regarding disclosure from investee companies

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Outcome, issuer's dynamic and perspective
To address this decrease, Carrefour set up an action plan in 2021, the results of which are
pending. Since 2021, the CSR index has been included in the variable compensation of all
employees in the group entity and of managers in integrated countries.
Furthermore, Carrefour has signed a global trade agreement that, among other provisions,sets out to protect female employees from violence at work and promote diversity and equal
opportunity in the workplace through joint initiatives, especially in relation to gender mix andnon-discrimination. Carrefour has also undergone gender equality audits and certification in
key areas of operation. In 2021, Corporate, Taiwan, Spain, Brazil, France, Argentina and Romania
maintained their GEEIS33 certification with Corporate, Brazil and Romania improving on theirprevious scores.
While there is still room for improvement, we recognize Carrefour’s efforts to improve theirperformance on gender equality and look forward to following their progress in the future.

Illustration 36: Sopra Steria – Beginning of the journey but a clear plan to get there
Context
At the end of 2020, Sopra Steria had 12% women in the Executive Committee and 32.5% overall.

ActionEngagement in the context of the 30% Club France Investor Group

Outcome, issuer's dynamic and perspective
The company set a new goal at the beginning of 2021 to reach 30% of women at the Executive
Committee level by 2025, a welcomed objective given the sector and 2020 baseline. To increase
female representation in top management, Sopra Steria has rolled out a senior managementtarget to get women to fill at least 20% of senior management by 2025 (versus 15%). The
target seems ambitious as senior management is expected to grow and promotion alone will
not allow to reach this target. While the company is at the beginning of its journey, it has aconcrete action plan to achieve these goals centered around three key themes:• Hiring (aims to at least maintain the proportion of women at all management levels andrecruit 33% more women for mid-management every year)• Promotion (deploying specific programs to help young talents climb the corporate ladder,e.g. mentoring)• Management practices (increasing awareness of stereotypes, business case for more diversity,
etc.)
Going forward, we will monitor the implementation of this plan, and reengage in the midterm
to ask for an improvement of the targets.

33. Gender Equality European & International Standards

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4. Support for research into responsible investment
mattersa. Supporting university chairs
Amundi actively supports academic researchand has forged several partnerships with
university chairs, especially regarding green
finance matters:– ESSEC is a leading business school inFrance. “ESSEC Amundi Chair in asset& risk Management” aims at promoting
academic research in the field of Assetand Risk management and stimulating thecooperation between ESSEC and Amundi
researchers, in particular in offering a seriesof research seminars on specialized topics
to Amundi collaborators and institutional
clients and diffusing the results of academic
research towards these collaborators.
– Academic Chair “Sustainable Finance andResponsible Investment”, created in 2007,
sponsored by the Association Française
de Gestion (AFG) and led by the École
Polytechnique and the Institut d’Économie
Industrielle (IDEI) in Toulouse.

– “Climate Economics Chair”, an initiative of
CDC Climate and Paris-Dauphine University
under the aegis of the Institut Europlace deFinance Foundation. We support its research
initiative “Carbon Prices and Markets”. These
initiatives contribute to enrich the research
capacities of Amundi.

b. Supporting PhD students
The ESG Method & Solutions team and the ESG
Research team welcomes three PhD students
working on the following topics:– “Green bonds: financial and extra-financial
performance”: comparative financial
analysis between green debt (green bonds)
and conventional debt, from the investor
and issuer’s point of view; extra-financial
analysis, strengths and weaknesses ofmarket development and developmentof environmental impact assessment
methodologies.
– “Sustainable development in the law of
the European Union’s external relations”:
analysis of how the European Union takes

into account the ideas of environmental
protection and social progress in the law
governing trade between the Union andthird countries; analysis of the relationshipbetween these two ideas and the search foreconomic progress within this same law.
– “Climate transition and physical risk”:
analysis on the risks to financial stability
behind climate change. Physical climate
impacts increasingly confront investors with
unplanned and abrupt changes or disruptions
to businesses or assets. In addition, investors
face transition risk to a lowcarbon andclimate-resilient future

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c. Creation of a Think Tank on Responsible Finance
Amundi created the Médicis Committee, aworking group dedicated to responsible finance.
This think-thank aims to address major current
social issues in terms of their relationship withfinance, with the goal to contribute to publicdebate, by enabling Amundi to fully endorse its
social role and be a different kind of financial
firm, owing to its understanding of and unique
outlook on the world around it. The Médicis
Committee, chaired by the Chairman of Amundi,brings together recognised figures from different
nationalities and backgrounds: economists,
philosophers, scientists, sociologists, businessleaders, representatives of non-profits, etc.
Their mission consists of: – Studying, froma multidisciplinary perspective, the major
economic, social, environmental issues that
our societies and economies face. – Creating
practical recommendations for financiers andbusinesses. – Encouraging the promotion of its
work.

October 2022

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Principle 11
Signatories, where necessary, escalate stewardship
activities to influence issuers.
When engaging companies, Amundi assesses the progress made by the issuer towards certain
objectives using milestones. Our first objective is to induce positive impact and the way we decideto engage will always be decided according to its expected effectiveness. When engagement
fails or if the remediation plan of the issuers appears weak, we may enact a mode of escalation
up to the point of exclusion from our active investment universe, meaning all actively managed
strategies over which Amundi has full discretion.

1. Measuring and monitoring engagement progress
Triggering deep change in large organizations
might prove to be complicated, disruptive
and even considered impossible by issuers.
This is why we seek consensus and action onreasonable staging posts during engagementmonitoring while not settling for progress
merely for the sake of progress. As investors
we must inflect ambition with the necessary
pragmatism 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 themes in sustainability climate, sciencebiodiversity, and human rights. We consider
sustainability to be an evolving benchmark, andas such our engagement strategies will evolve
over time to better improve integration of thesedevelopments.

2. Engagement escalation: to have an impact we needto incentivise change when momentum is slow
Engagement escalation modes include (in noparticular order):– negative overrides to potential or continued
investment in one or several criteria– questions at AGMs
– votes against the discharge or the renewal ofboard members– filling of resolutions– public statements– ESG score caps (main example is tobacco
policy: an issuer that has more than 10% of its
headline revenue coming from tobacco has
its rating capped as E),– and ultimately exclusion.

We might use escalation modes through ourvoting activities. For example, in the case ofthemes that are critical (such as climate, natural
capital preservation, social matters, severe
controversies and/ or violations of Global
Compact principles) or lack of response on
engagement related to sustainability factors,
Amundi can decide to vote against the discharge
resolution. In the case of long-standing inaction,or if the case is severe, Amundi can vote against
the chairperson or some board members.

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In addition to exercising escalation through ourvoting activities, failed engagement might havea direct impact on our full capacity to invest in
a company. Indeed, ESG Research analysts candowngrade the related criteria in the ESG scoreof the issuer, and in the case of a critical issue,
the overall ESG score can be downgraded.
Amundi is committed to integrating ESG criteria
into the investment process of actively managed
open-ended funds34 and seeks to maintain,
in addition to financial objectives, an average

October 2022

portfolio-level ESG score above that of therespective investment universe. Occasionally,
an issuer's ESG rating can change from being
investable to excluded due to its obstinacy on
an ESG issue that we believe to be crucial.
The ultimate escalation mode is exclusion, incase of failure to engage and remediate on a
critical issue.

Case study 21: HSBC - Filing and Co-Filing Shareholder Resolutions to Push the
DialogueAmundi was part of a group of large investors led by ShareAction that filed a climate resolution
ahead of HSBC’s AGM of January 2021.

Context
HSBC had committed to reach Net Zero emissions by 2050, but a pathway on how they would
reach this target was missing, as well as a clear plan to phase out from fossil fuels. Underpressure of a group of investors including Amundi, HSBC filed a board-backed resolutioncommitting the bank to disclose a sustainability strategy including an alignment of its financing
activities with the objective of the Paris Agreement and a phasing out of thermal coal by 2030
in the OECD and by 2040 in the rest of the world.

ActionOn the back of this company-proposed resolution, the co-filing investors, including Amundi,
agreed to withdraw their motion and instead support the bank’s proposal during the AGM in
May 2021.
Nonetheless, Amundi has continued its engagement with the bank in 2021, notably after thebank announced its climate strategy in December. Amundi has asked HSBC management
to expand the thermal coal exclusion policy to its asset management activities, with an
implementation or at least public announcement during the first quarter of 2022.

Perspective
In the absence of response, Amundi might consider escalation. Additionally, Amundi has asked
for a refinement of the coal developers’ definition, to reassure on the exclusion of indirect
financial support to new thermal coal assets. Amundi will consider presenting a resolution at
the 2023 AGM.

34. See Amundi’s responsible investment policy https://about.amundi.com/

109 Stewardship Report 2021

October 2022

Case study 22: Credit Suisse & Deutsche Bank - Raising questions in AGMs toemphasise areas where issuers need to improve

Another escalation mode used in 2021 was to ask public questions in AGMs. Amundi feels thatraising questions during AGMs is an efficient way to emphasize areas where issuers need to
improve. In 2021, we concentrated this action on issuers having direct or indirect coal exposure.

Credit Suisse
Amundi submitted, together with six other institutional investors, a joint statement ahead of
the 2021 AGM of Credit Suisse, following extensive engagement on their energy policy andclimate strategy. Notwithstanding the bank’s strengthening of its coal policy in August 2020,
it has not committed to a full coal phase out yet. We also asked for an exclusion policy on
coal developers, for a commitment to help clients implement coal phase out plans, and for the
publication of more information on the expected transition strategies of clients.

Deutsche Bank
Regarding Deutsche Bank, following a lack of answers tou our previous engagements, Amundi
submitted questions at the 2021 AGM related to their fossil fuel policy. We asked the bank to
put in place an exclusion policy for coal developers and a phase out plan from thermal coal inline with the Paris Agreement.

110 Stewardship Report 2021

October 2022

Case study 23: Credit Suisse - Escalation following a controversy
Context
Following its most recent controversies (Greensill & Archegos), Credit Suisse announced
several measures in April 2021:– the departure of some executive members, including the head of the CIB department– a cut in the dividend and a suspension of share buybacks– the cancellation of the Executive Board’s 2020 bonuses and 2021 long term incentive– waive by outgoing chairman of his CHF 1.5Million annual chair fee– two investigations by independent external parties into the supply chain funds matter andthe Archegos-related matter
These controversies have raised considerable concerns about the bank’s risk management
system, business ethics up until the highest levels and audit & control mechanisms. The
measures taken were not sufficient to allay our concerns, therefore a call was organized with
two Board Members on April 9th 2021 with the Chairpersons of the Compensation and Audit
Committees.

ActionAmundi expressed its concerns on the company’s ethical practices, the delegation and controlof risk from the top to lower levels in the organization and the balance between risk andprofitability.
Following the discussion, it was decided to not support at the 2021 AGM:
– Reelection of some board members due to a failure of their control duties– All Remuneration items ex ante and ex post linked to the Chairman and the Executives
members

Perspective
A follow up will be organized before AGM 2022 to assess the corrective measures implemented
and the improvements realised.

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Stewardship Report 2021

Case study 24: Governance issues for a Japanese automotive manufacturer –Downgrade of the ESG rating

Context
Amundi 2020 stewardship report mentionedthat we have been engaging with a Japanesemanufacturer since 2019 on governance issues.

ActionAmundi maintained pressure on this company toencourage better practices.
In the absence of changes, we decided todowngrade our ESG rating and informed thecompany that a divestment would follow if noimprovements were observed in the near future.

OutcomeThe June 2021 AGM of the company confirmed
the improvement in governance as the percentage
of independent directors increased from 20% to
40%, and one new female director was appointed.

October 2022

112 Stewardship Report 2021

October 2022

EXERCISING RIGHTS AND RESPONSIBILITIES

Principle 12
Signatories actively exercise their rights andresponsibilities
We regard the considered and intelligent exercise of investor voting rights as a central aspectof our role as a responsible investor. Our voting policy responds to our holistic analysis of all the
long-term issues that may influence value creation, including material ESG issues. Furthermore,
our voting reflects our overall approach to stewardship, meaning that we are committed to longterm relationships with the companies in which we invest, and to active dialogue with them.

1. Our vision of exercising voting rights________The Voting & Corporate Governance teamconsists of 7 specialists who analyse resolutions
and organize ongoing dialogue with companies
pre and post AGM’s with the aim of:– Being a responsible investor through theexercise of the voting rights following aclear voting policy that encourages strong
governance and accountability of boards andmanagement on environmental and social
issues,– Encouraging adoption of governance bestpractices through pre-and post AGMs
dialogue, either by highlighting key elementsof our voting policy and when possible byalerting the issuers when we intend to voteagainst a resolution with a clear rationale,– Using the structure created by proxy voting
to invite feedback and dialogue fromcompanies on issues we have raised via theballot– Taking the opportunity to raise awarenessamong board members of the challenges andopportunities that the transition towards asustainable, inclusive low carbon economy
could pose on their long-term businesssuccess, the necessity for them to handle it atboard level and be accountable to the AGMs.
As part of its regular dialogue with issuers,
Amundi informs companies of our proprietary
methodology for ESG analysis and the rating
assigned to them, and explains any changes.
The positions we express in our votes should notsurprise companies. They are the result of ouranalysis and dialogue, based on fully transparent
criteria. Amundi has centralised the exercise
of voting rights35 within a Voting & Corporate
Governance team and exercises the votes onbehalf of its subsidiaries and funds. Amundi iscommitted to transparency and, where possible,
it informs issuers of planned negative votes.
In 2021, Amundi has significantly increased thenumber of active dialogues with issuers aroundthe AGMs season.

35. Amundi Aalan Sdn Bhd (Malaisie), Amundi Asset Management, Amundi Austria, Amundi Canada, Amundi Deutschland,
Amundi Hong Kong, Amundi Iberia Amundi Immobilier, Amundi Ireland, Amundi Japan, Amundi Luxembourg, Amundi
Sgr, Amundi Singapore mandates, Amundi UK Ltd. BFT IM, CPR AM, Etoile Gestion, Sabadell Asset Management, Société
Générale Gestion

113 Stewardship Report 2021

October 2022

2021 Voting Engagements Statistics
The Amundi Corporate Governance team conducted dialogue with 1,033 issuers in 2021.
Breakdown of Voting Engagements

Geographic Breakdown of Voting Engagements
Number of engagements

Number of engagements
Voting - Intentions’alerts*

654

North America

Dialogues triggered by voting alerts**

159

EuropePre-AGM and Off-Season Engagements

220

Total

1033

* with no further dialogue.
** with no off-season dialogue.

Emerging Markets
Developed Asia
0 50 100 150 200 250 300 350 400 450

Source : Amundi Asset Management

2. Amundi’s voting policy____________________
Amundi intends to fully exercise its responsibility
as an investor by voting at general meetings
according to this voting policy36.
Amundi has developed its voting policy
according to its holistic analysis of all the longterm issues that may influence value creation,
including material ESG issues. Our voting policy
is supported by our own data and KPIs. A
portion of the analysis is performed in-house,
mainly on priority issues and companies. Part ofthe custom analysis is performed by an external
provider. This is supplemented by the analysisof three different proxy advisors. The policy isreviewed on an annual basis and available on our
corporate website.
The key elements of the voting policy include:– Shareholder rights: A corporate governanceregime must protect and facilitate theexercise of shareholders’ rights and ensure
fair treatment of all shareholders, including
minority and foreign shareholders.
– Boards, committees and governing bodies:
Boards have strategic authority and theirdecisions affect the future of their company,
both in the short and long-term; all board
members have individual responsibility.

Boards are accountable to the company
and its shareholders, but must also have
due regard to, and respect the interests of,other stakeholders. In particular, employees,
creditors, customers and suppliers.
Compliance with social and environmental
standards is also a board responsibility.
Amundi is fully backing the eight principlesof the World Economic Forum’s Climate
Governance Initiative. For a board to beeffective, a fair level of independence anddiversity is needed as well as a limitation ofover-boarding.
– Compensation policy & dividends: weanalyse executive compensation holisticallyand vote based on two main criteria: theCEO’s compensation must be reasonable, andeconomically justified. Further, we are vigilant
to ensure that the company’s pay approach,and more broadly its sharing of value overall,
do not generate unacceptable situationsof social inequality. Since 2019, we havereinforced our voting and engagement effortson these topics. Pronounced socioeconomic
inequalities are detrimental to GDP growth ,and even though inequalities have different
grounds, corporates have an impact on them.

36. The policy is reviewed on an annual basis and available for review on our corporate website.

114 Stewardship Report 2021

Therefore, we have reinforced our dialogues withcompanies concerning the critical need to focus
on the long term while balancing the different
stakeholders’ efforts with a conservative
approach on dividend payment and temperance
in executive compensation. Social cohesion,
wage balance, and employee involvement in thecompany’s growth have long been engagement
topics for Amundi. We are also vigilant on the
inclusion of ESG performance criteria in thevariable remuneration as well as KPIs related toclimate for issuers from the climate high impact
sectors.

October 2022

– Amundi favourably views shareholder
resolutions asking issuers to increasetransparency on environmental and social
issues. Each environmentally or sociallyrelated shareholder resolution has been
analysed by a corporate governance analyst,
when needed with the help of an ESG analyst,
to assess the value of the proposal for theshareholders.

3. Scope of the voting policy_________________
This voting approach applies to all Amundi
managed funds, apart from some whose overallvalue is less than EUR 15 million, because wehave concluded that the costs of voting on suchfunds outweigh the benefit to clients. In the sameway, voting rights are exercised on the entiretyof the shares held, unless the required period
during which trading is blocked by the market or
custodian risks an adverse impact on our clients
because it would hinder portfolio manager
trading discretion. Exceptionally, we may not beable to ensure effective voting for some or all of
the shares held. The funds exercise their voting
rights at the meetings of the companies inwhich they have an equity investment wheneverpossible.
For 2021 we have voted on all holdings where
it was economically viable to do so, which was
95% the total of the votable assets under the
responsibility of Amundi (which means we havevoted on more than 7300 AGMs). When the
management of an equity portfolio is trusted
to an outside manager, that manager may havethe voting rights, as provided in the delegation
contract. Clients with segregated mandates
can require us to apply their own voting policy.
Voting rights are exercised for securities heldin the portfolio at the time of the General
Meeting. To fully exercise these rights, the lentsecurities are recalled in accordance with local
laws, technical constraints, and the interest of
the meeting. Shares are recalled for all meetings
considered sensitive. For the SRI labelled funds,
shares are systematically recalled for all issuers
several days before the meeting record date inorder to hold the rights to vote at the meeting.
Full disclosure of all our latest voting decisions isavailable on our corporate website.

115 Stewardship Report 2021

October 2022

Proxy-voting flowchart
Amundi voting policy*
Amundi voting rules*
Other
Votes instructedfollowing ourcustom policy whichapplies our voting
rules.

Qualitative universe
The Corporate Governance team (the Team) analyzes
the compatibility of the proposals with the voting policy
so as to determine the best voting intentions for every
proposal.

If the issue is notcovered by the voting
policy (ex. non routine
financial operations),
then the Team asks the
ESG team or Voting
committee members fortheir opinions.

If votingintentions in linewith the voting
policy can be
determined, thevote is instructed.

If the Team
identifies
a conflictof interest:
preparation ofan explanatory
file for the
VotingCommittee.

Access to internal
expertise,access to external
expertise & custom
recommendations,dialogue withissuers.

If the initial voting
intention based onpolicy does not seemto be in the client’s
interest, then theTeam asks the Voting
committee for theiropinions.

If no clear view emerges orif the agreed voting
intention in breach of thevoting policy, then the Teamasks the Voting Committee
for a decision.

Voting Committee: Chaired by the ESG Supervisor, member of the Amundi Management
Committee,
it includes Senior Managers from investment, financial and extra-financial analysis,
as well as external advisors.
The Committee determines Amundi voting policy and the voting rules.
On cases presented to the committee, it will decide the vote which is then instructed.
* Reviewed on a yearly basis

4. Exercising our voting rights in a considered andresponsible manner________________
Good governance practices are paramount toprotecting the interests of minority shareholders.
The exercise of voting rights at the Annual
General Meeting is therefore key to expressing
an opinion on the company’s strategy andoperational and financial management. Thismeans that being able to vote in proportion
to the ownership of the capital and not being

faced with limitation or protection mechanismsthat would allow the company to circumventthe decision-making power of its shareholders.
Amundi funds have exercised in 2021, wheneverpossible37, the voting rights at the meetings ofthe companies in which they have an equity
investment38.

37. 95% of the shares held of portfolios of our voting universe. Ballots’ failures are explained by operational problems
38. See appendix of the voting policy for the exact description of the voting scope https://www.amundi.com/institutional/

116 Stewardship Report 2021

Certain high-level governance principles that areworth defending universally such as independent
oversight and agents’ remuneration being alignedwith their principals’ interests. As far as possible,
we express these consistently in our voting in
all jurisdictions. Nevertheless, cultural norms dovary to the extent that it is not always productive
to maintain this stance to the same degree andwe must accept a slower pace of change over nochange at all. The implementation of this policy
is adapted to knowledge of the limit of what is
possible each of these local contexts and this iswhere we seek to position our votes.

October 2022

Our decisions are always made with a view
to defending the interests of our clients bysupporting the creation of sustainable longterm value. To do that, Amundi considers eachcompany’s context in a pragmatic manner tomake sure its voting decisions are effective,
especially regarding gender diversity forexample. In that case Amundi may link the votewith a specific engagement stream39.

5. Questions in AGMs & voting against management
as an escalation mode
Apart from the traditional AGM items on
which Amundi votes using its voting policy(compensation policy, dividends, independenceof the board, over-boarding, diversity ofprofiles), Amundi has used votes to express
concerns following failed engagements or incase of failure to act responsively on topics
representing systemic risks such as the energy
transition, coal phase-out, and social cohesion.
Amundi voted against the discharge of theboard or management, or the re-election of the
Chairman and of some Directors in the following
cases:– Companies that are excluded from the active
investment universe according to the Amundi
Responsible Investment policy but held
elsewhere for example in index funds– A selection of companies with a poor climate
strategy operating in sectors for whichtransition is paramount for the alignment with
the Paris Agreement.

➜ Key Outcomes and examples of the 2021 Voting Campaign
The 2021 season was generally characterized by opposition votes for four main reasons:– Unbalanced remuneration practices or lack of ESG/ climate-related KPIs
– Unsustainable dividends during a global pandemic– Over boarding, the term used to describe when a board member has, in our view, more
executive and/or non-executive positions that he or she can reasonably discharge to a highstandard– Failure to factor in climate issues or questionable social practices
Where possible, Amundi endeavours to alert issuers if it intends to vote in opposition by sending
an email prior to the meeting. This will explain the rationale for the intended voting stance.

39. See Japanese engagement on gender diversity in the boardroom for an example

117 Stewardship Report 2021

October 2022

Voting statistics

2018

2019

2020

2021

Number of companies voted

2 574

2 931

3 397

4 008

Number of meetings voted

2 956

3 474

4 241

7 309

Meetings voted with at least one vote “Against Management”

62%

56%

71%

64%

Number of items voted

35 24541 34649 96077 631

Number of items voted “Against Management"*

15%

13%

20%

20%

Votes “Against Management”

2018

2019

2020

2021

Board structure

11%

11%

19%

20%

Compensation

36%

27%

31%

45%

Financial Structures

26%

21%

28%

21%

Vote in favour of Shareholders proposals

2018

2019

2020

2021

% of votes in favour of shareholder resolutions

66%

65%

67%

77%

Climate

82%

81%

87%

86%

Social/Health/Human Rights

55%

70%

81%

83%

ESG Items

2018

2019

2020

2021

Environment / Climate

108

133

148

196

Social

4 036

4 380

5 503

7 398

Governance

31 10136 83344 30970 037

Proportion of votes “Against/Category”(*) Does not include vote which there was no management recommendation

Regional breakdown of meetings

4000
3500
3000
2500
2000
1500
1000
500
0
Developed
Asia

Emerging
Markets

EuropeNorth
America

118 Stewardship Report 2021

20%

Opposition Rate Globally

In 2021, the opposition rate on compensation
was

45%

In 2021, the opposition rate on dividends was

15.5%

October 2022

86%

In 2021, Amundi supportedof climate-related shareholder resolutions
presented at the General Meetings in which it
participated.
In 2021, Amundi supported

83%

of social, health & humanrights related shareholder resolutions
presented at the General Assemblies in which
it participated.

Executive compensation

Climate strategy

Amundi considers that the alignment of interests
between managers and shareholders is a key
part of corporate governance. The remuneration
policy within the company must reflect andmaintain this balance. In 2021, Amundi paid close
attention to whether executive remunerationplans and practice did not reward short-termtargets at the expense of long term growth aswell as balancing the different stakeholders’efforts. We also expect the inclusion at board
executive and ideally senior management level
ESG KPIs and KPIs related to climate for issuers
from the climate high impact sectors.

We also supported a large majority of shareholder
resolutions calling for more transparency andinformation on ESG and climate strategy. Thiswas recognized by ShareAction’s “Voting
matters 2021” report in which Amundi ranks
amongst the top performing asset managers
in terms of voting on climate change, climaterelated lobbying, and social issues.

Dividends
We strongly believe, especially in light of thecurrent pandemic, that dividend policies should
balance shareholders needs for remunerationin cash, with the need to preserve the financial
strengths of the company as well as the longterm interest of employees to pave the way for
future earnings growth.

Board structure
Amundi expects to have a full understandingof the functioning of the governance bodies
including: – the level of independence – existence
and operation of specialized committees – skills
and background balance – adequate availabilityof directors (absence of “over-boarding”)

Social, Health & Human Rights Related
Resolutions
Social, health & human rights related resolutions
have increased at General Meetings.

Focus on Say on Climate
2021 has seen the development of a new type of resolution called ‘Say on Climate’. Those
resolutions related to the climate strategy of the issuer are presented by management. Because
climate change could provoke destructive chain reactions and constitutes a systemic risk,
Amundi believes that shareholders should be fully informed on how companies are tackling thischallenge and are contributing to the global effort to transit towards a low carbon economy
in line with the Paris agreement. Amundi views the development of such resolutions as a clear
improvement for the shareholder democracy. Therefore, we have backed those resolutions
especially where the issuer strategy is deficient.

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October 2022

Case study 25: Say on Climate

2021 saw a notable expansion of management sponsored advisory votes on climate transition
plans (“Say on climate”). Two US companies and an additional eighteen European companies
tabled such proposals. These proposals were broadly supported, in part because of theirnovelty nature.
However, best practices on the structure of such proposals and related disclosures are yet tobe established. Amundi decided that it was more efficient to vote in favour of “Say on Climate”
in the first year (2021), even when the plans presented had significant room for improvement,
and to engage the companies so as they increase their ambition level. Negative votes will beconsidered for the following years40.
Amundi has engaged several issuers, directly or with the French Eurosif, a sustainable investment
forum, on the need for shareholders to be able to vote on Say on Climate resolutions.
We ask for two resolutions, one ex-ante on the strategy and one ex-post on the result.
We ask that the Climate strategy covers the important elements using a recognized framework
if possible, including (without limitation) short, mid & long term targets on gross emissions
and on the different scopes and capital expenditure planned. We also highlighted the needfor the board to discuss the result of stress testing of the business model using carbon prices
consistent to Net Zero scenarios, or even higher prices, as well as the importance for the board
to collectively acquire the right competencies.

40. In 2022, Amundi has created a framework of analysis for this type of resolution, resulting to an opposition rate for the
first semester of around 60%.

120 Stewardship Report 2021

October 2022

Case study 26: Voting on climate strategies
Equinor ASA / Climate Strategy
At the 2021 General Meeting of Equinor, a shareholder proposal requested the company to stop
all Oil and Gas Exploration in the Norwegian Sector of the Barents Sea. Amundi supported thisresolution to voice its concerns about exploration activities in this region of the arctic seas.
We wrote to the company to inform them of our vote and to propose a call. As our message
remained unanswered, we will continue to monitor the company’s practices and may decide tovote against the management on other proposals in the future.

Clariant/ Board structure
In March 2021, Amundi informed the issuer of our voting intention to not support the re-electionof two board members for over-boarding issues. One member holds five mandates (of which
two are as Chair of the board) and the other holds three mandates (of which one are as Chairof the board and two as Chair of the audit committee).
The nominees received 73% and 94% support.
The issuer took note of our concerns. Amundi will keep monitoring the issue and will voteagainst the re-election of these board members if they do not reduce their number of mandates
as we consider the time availability of board members to be a critical topic.

McDonald Corporation/ Social, Health & Human rights related resolutions
Trinity College, the University of Cambridge and Amundi co-filed a shareholder proposal at the2021 annual shareholder meeting of McDonald Corporation. We asked the company to study
and disclose the external environmental and public health costs created by the use of antibiotics
in its meat supply chain. Excessive use of antibiotics in raising animals for food contributes toantimicrobial resistance (AMR), which threatens global health by reducing the effectiveness ofantibiotic drugs. We believe it is shareholders’ interest to demand more transparency and to
be able to verify that the Company does not seek profits over behaviour that threatens socialand environmental systems.
While the proposal ultimately failed, it received the support of 11.27% of shares voted. By co-filingthis proposal, Amundi has been able to signal to the Company’s Board and management that
more and more shareholders were concerned by these risks and that additional disclosure was
expected on the matter. After a similar proposal had been filed by The Shareholder Commonsat the KFC, Pizza Hut and Taco Bell parent company Yum! Brands, the company committed todisclose the systemic costs of antibiotic use, so the co-filers decided to withdraw the proposal.

Starbucks Corporation/ Social, Health & Human rights related resolutions
Shareholders of Starbucks Corporation urged the board to adopt a policy to promote significant
representation of employee perspectives among corporate decision makers. They required theinitial list of candidates from which new director nominees are chosen by the Nominationsand Governance Committee to include non-management employees. Amundi is in favourof employee involvement in corporate governance (as well as employee share ownership),because these practices help align the interests of shareholders and employees over the longterm. Amundi thus promotes the appointment of employee Directors as a principle of good
governance. We therefore supported the proposal.

121 Stewardship Report 2021

October 2022

Amundi informed the company of its voting intentions and held an engagement call to express
its views. The proposal failed at the AGM, with a support rate of 7.2%. While we understand thatthe topic of employee representation on the Board is still considered marginal in the UnitedStates, Amundi will keep engaging with companies on that topic to explain our position andthe benefits of the practice.

3M Company/ Social, Health & Human rights related resolutions
The proposal encouraged the consideration of pay disparity between Executives and Other
Employees when setting target amounts for CEO compensation. Amundi believes that social
cohesion, or its absence, represents a systemic risk for companies. It can also be an opportunity
for those who wish to integrate it in a positive way, in particular through controls of the wagebalance within the framework of compensation policies. Amundi therefore considered that this
proposal had merit and supported it.
Amundi informed the Company of its voting intentions but the Company was unresponsive.
The proposal failed at the AGM, receiving the support of 10.8% of the votes cast.

Chartwell Retirement Residences / Social, Health & Human rights related resolutions
The proposal requested that the Board of Directors undertake a review and report toshareholders on the feasibility, cost and benefits of the company implementing a Living Wage
policy covering employees, suppliers and contractors. Amundi supports living wage policies
especially in at risk sectors such as retirement services.
The proposal failed at the AGM, gathering only 7.2% of the votes. The low level of support isevidence that the topic of living wages is still in the infancy phase and more education needs
to happen both at the investor and company levels on the materiality of the topic. Amundi ispart of the Platform Living Wage Financials (PLWF), an alliance of 19 financial institutions thatengages companies on the issue.

122 Stewardship Report 2021

October 2022

Appendix 1
ESG policies and reports, ESG Reporting
Transmission
methodDocument nameContents

Frequency

Responsible
Investment Policy

Amundi's Responsible Investment policy

AnnualESG Corporate
Ambition 2025

Amundi’s Responsible Investment
ambitions to be completed by 2025

Shareholder
Engagement
Priorities

A report summarizing the outcome of theprevious engagement, voting campaign,and outlining the objectives for the current
year.

Annualwww.amundi.com

Engagement report

Details of Amundi's engagement process,results of our dialogue and engagementwith companies on topics related to ESG
matters

Annualwww.amundi.com

Voting policy

Analytical framework for Amundi's voting
policyAnnualwww.amundi.com

Amundi Sustainable
Finance Disclosure
Regulation
Statement33

Corporate sustainability-related disclosures(“SFDR”) with regard to EU regulationin the financial services sector including
Principal Adverse Impacts

Annualwww.amundi.com

UN PRI Public
Transparency
ReportAmundi's annual report regarding its
ESG reporting obligations arising from its
adherence to Principles for Responsible
Investment (PRI)

Annualwww.amundi.com

UN PRI Climate
Transparency
ReportAmundi's annual report regarding its
Climate reporting obligations arising fromits adherence to Principles for Responsible
Investment (PRI)

Annualwww.amundi.com

TCFD Climate
ReportingAmundi’s response to TCFD requirements
and Article 173 of the French Energy
Transition for Green Growth Act.

Annualwww.amundi.com

Report on
voting rights
and shareholder
dialogue

Implementation of Amundi's voting policy

Annualwww.amundi.com

ESG reporting

For SRI funds: the portfolio's ESG ratings,
those of its benchmark and/or theinvestment universe

Monthlylwww.amundi.com

www.amundi.com
www.amundi.com

Environmental, Social, and GovernanceIndicators
SRI transparency
code

AFG-FIR/EUROSIF transparency code forAmundi SRI funds

Annualwww.amundi.com

Social impact
reporting

For social-impact funds: details of social
impact investments by topic (employment,
housing, health care, education, nonprofit services, international solidarity,environment), list of social impact
companies funded, and testimonials

Annualwww.amundi.com

CSR Report

Annual report on Amundi’s corporate social
responsibility actions and results.

Annualwww.amundi.com

123 Stewardship Report 2021

October 2022

Standard
ESG reporting
AMUNDI FUNDSGLOBAL ECOLOGY ESG - A EUR

Detailed ESG reporting

In addition to complying with Amundi’s
AMUNDI FUNDS GLOBAL ECOLOGY ESG - A EUR
Responsible
Investment
Policy,ESG
EQUITY ■mainstreaming
portfolios have a performance
objective
EQUITY ■ that aims to achieve a portfolio ESG
score above that of the reference universe.

It makes it possible to view the portfolio's
ESG ratings (ratings from A to G, A being thehighest rating and G the lowest) and comparethat portfolio to other ratings in its investment
universe. The data comes from the configuration
created by our IT teams and connected to the
ESG rating and management tools.
FACTSHEET

Marketing
FACTSHEET
Communication

MarketingCommunication

28/02/2022

Average ESG rating (source : Amundi)

28/02/2022

Environmental, social and governance rating

Average ESG rating (source : Amundi)

ESG Investment Universe: 100% MSCI WORLD
ESG
Investment Universe: 100% MSCI Europe Value

Environmental, social and governance rating

ESG Investment Universe: 100% MSCI WORLDESG Coverage (source : Amundi)

ESG Coverage (source : Amundi)
Percentage with an Amundi ESG rating ²
Percentage that can have an ESG rating ³

Percentage with an Amundi ESG rating ²
Percentage that can have an ESG rating ³

Portfolio
97.69%
97.69%
Portfolio

97.69%
97.69%ESG Investment Universe
99.63%
100.00% Universe
ESG Investment

99.63%
100.00%Investment Portfolio Score: 1.06

Investment
Portfolio
Score:Score¹:
1.06 0.77
ESG Investment
Universe
ESG Investment Universe Score¹: 0.77

ESG Terminology
ESG Terminology

ESG
Terminology
ESG criteria

ESG Rating

Amundi ESG Mainstreaming

The criteria are extra-financial criteria used to assess theEnvironmental,
ESG
criteria Social and Governance practices ofcompanies, states or local authorities:
The criteria are extra-financial criteria used to assess theEnvironmental, Social and Governance practices ofcompanies,
states or(energy
local authorities:“E” for Environmentand gas consumption levels,
water and waste management, etc.).
“S” for Social/Society (respect for human rights, health andsafetyin the workplace,etc.).
“E”
for Environment(energyand gas consumption levels,“G” forGovernance(independence
water
and
waste management,etc.).of board of directors,
respect
for shareholders’rights,“S”
for Social/Society(respect
foretc.)human rights, health andsafety in the workplace, etc.).
“G” for Governance (independence of board of directors,
respect for shareholders’ rights, etc.)

In addition to complying with Amundi Responsible
The issuer’s ESG rating: each issuer is assessed on the4, Amundi ESG Mainstreaming portfolios
basis Ratingof ESG criteria and obtains a quantitative score, theInvestment
PolicyESG
Amundi ESG
Mainstreaming
scale of which is based on the sector average. The score ishave an ESG performance objective that aims to achieve a
In addition
to scorecomplying
Responsible
The
issuer’s
rating:issueron theto G
translated
intoESGa rating
on aeachscale
fromisA assessed(highest rating)portfolio
ESG
abovewith
the Amundi
ESG scoreof their ESG
basis
ofrating).
ESG criteria
and obtains
a quantitativescore,(lowestThe Amundi
methodology
providesfor atheInvestmentuniverse.
Policy4, Amundi ESG Mainstreaming portfolios
Investment
scaleof which isstandardised
based on theandsectoraverage.analysis
The scorecomprehensive,
systematicof ishave an ESG performance objective that aims to achieve atranslated
into alla rating
on a scalefromA (highest
rating) to G
issuers acrossinvestment
regionsandasset classes
portfolio ESG score above the ESG score of their ESG(lowestrating).
The
Amundi methodology provides for a(equities,
bonds,etc.).
Investment universe.
comprehensive,standardised
systematic
analysisof
ESG rating of theinvestmentand
universe
and theportfolio:
issuers
acrossalltheinvestment
regions
and areasset
classes
the portfolio
andinvestment
universe
given
an ESG(equities,score andbonds,
an ESGetc.).
rating (from A to G). The ESG score
corresponds
theinvestment
weighted averageof thescores,ESG
rating oftothe
universe
andissuers’
the portfolio:
calculated
accordingto their relative
weightingin thetheportfolio
and the investment
universe
are given
an ESG
investment
universe
or in (fromthe portfolio,liquidscore
and anESG rating
A to G). excluding
The ESG score
assets and non-rated
issuers.average of the issuers’ scores,
corresponds
to the weighted
calculated according to their relative weighting in theuniverse oror anin theportfolio,
excluding¹ The investment universe reference is defined by either the fund'sinvestment
reference indicator
index
representativeof liquid
the ESG-related investable universe.
assetsand non-rated² Percentage of securities with an Amundi ESG rating out of the total
portfolio(measuredissuers.
in weight).
³ Percentage of securities for which an ESG rating methodology is applicable out of total portfolio (measured in weight).
Theinvestment
updated document
availableisatdefined
https://www.amundi.com/int/ESG.
¹⁴The
universe isreferenceby either the fund's reference indicator or an index representative of the ESG-related investable universe.
² Percentage of securities with an Amundi ESG rating out of the total portfolio (measured in weight).
³ Percentage of securities for which an ESG rating methodology is applicable out of total portfolio (measured in weight).
⁴ The updated document is available at https://www.amundi.com/int/ESG.
Sustainability Level (source : Morningstar)
Source Morningstar ©
Sustainability Score - based on corporate ESG risk
analysis provided by Sustainalytics used in the
Sustainability Level (source : Morningstar)calculationof Morningstar's
sustainability score.
SourceMorningstar©
© 2021 Morningstar.
rights reserved.
The information
Sustainability
Score All- basedon corporate
ESG risk
contained
here:
(1)
is
owned
by Morningstar
and in/ or theits
analysis provided by Sustainalytics
usedcontent providers;(2) may
not be reproducedor
calculationof Morningstar's
sustainability
score.
redistributed;
and (3) are
not guaranteed
to beinformation
accurate,©
2021 Morningstar.
All rights
reserved. The
The sustainability level is a rating produced by Morningstar
completeortimely.
Neither
Morningstar
nor
its
content
contained here: (1) is owned by Morningstar and / or its
that aims to independently measure the level of responsibility
providers providers;
are responsible
for anyor losses
content(2) may
not damages
be reproducedorof a fund based on the values in the portfolio. The rating
arising from theuse(3)ofare
thisnot
information.
Past
redistributed;
andguaranteed
to performancebe accurate,
ranges
from
very
low
(1
Globe)
to
very
high
(5
Globes).
The sustainability level is a rating produced by Morningstar
isnoguaranteeoffutureresults.
For
more
informationoncomplete or timely. Neither Morningstar nor its content
that aims to independently measure the level of responsibility
the Morningstar
Rating, forpleasesee their orwebsite
providers
are responsible
any damages
lossesof a fund based on the values in the portfolio. The ratingwww.morningstar.com.
arisingfrom the use of this information. Past performance
ranges from very low (1 Globe) to very high (5 Globes).
is no guarantee of future results. For more information on
the Morningstar Rating, please see their website
www.morningstar.com.

The ESG report includes the following
sections:– Definitions of the ESG criteria– The average ESG rating in the portfolio– The assessment for each ESG criterion– The ESG analysis coverage– Impact indicator criteria• Environment: Carbon footprint per million
euros in revenue• Social : Manager Diversity (averageamundi.com
percentage of female managers)• Governance: Board Independence
Percentage (percentage of directorsthat meet the designated criteria for
independence)• Human Rights Compliance: Decent working
conditions and freedom of association(percentage of companies with policies that
exclude forced or obligatory child labouror that guarantee freedom of association,
applied universally regardless of local laws.)

For "retail" investors information

amundi.com

For "retail" investors information

124 Stewardship Report 2021

October 2022

AMUNDIACTIONSEURO ISR - I
SampleESG
reports
FACTSHEET
31/10/2020

EQUITY ■SRI Terminology

SRI according to Amundi
Rating scale from A (best score) to G (worst score)Socially Responsible Investment (SRI)

ESG criteria

The SRI expresses sustainable development objectives ininvestment decisions by adding Environmental, Social andGovernance (ESG) criteria in addition to the traditional
ﬁnancial criteria.

The criteria are extra-ﬁnancial criteria used to assess theEnvironmental, Social and Governance practices ofcompanies, states or local authorities:

SRI thus aims to balance economic performance and socialand environmental impact by ﬁnancing companies and public
entities which contribute to sustainable development
whatever their business sector. By inﬂuencing thegovernance and behaviour of stakeholders, SRI promotes a
responsible economy.

“E” for Environment (energy and gas consumption levels,
water and waste management, etc.).
“S” for Social/Society (respect for human rights, health andsafety in the workplace, etc.).
“G” for Governance (independence of board of directors,
respect for shareholders’ rights, etc.)

An SRI portfolio follows these rules :1 - Exclusion of E, F and G scores ¹
2 - Overall portfolio rating of C or above
3 - Overall portfolio rating above the benchmark
index/investment universe rating
4 - ESG rating for 90% minimum of portfolio stock ²

Average ESG rating
Environmental, social and governance rating

Of Portfolio²

From the universe of reference³

7.49%

A

35.86%

3.47%
B

47.16%

BC

8.69%

A

31.18%

B

44.50%

DC

15.24%

D

0.67%

E

5.36%

0%

F

0%

F

0%

G

0%

G

0.13%

not rated

0.25%

Evaluation by ESG criteria

C+E

not rated

Benchmark : MSCI EMU

Environment
SocialGovernance

C+
C
B-

Overall Rating

B-

Coverage of ESG analysis
Number of issuers in the portfolio% of the portfolio with an ESG rating²

131
99.87%ISR Label¹ If an issuer's rating is downgraded to E, F or G, the manager has a period of three months in which to sell the security. A tolerance is authorized for buy and hold funds.
² Outstanding securities in terms of ESG criteria excluding cash assets.
³ The investment universe is deﬁned by the fund's reference indicator. If the fund does not have an indicator, it is deﬁned by type of security, geographic zone and investment themes andbusiness sectors.
Amundi Asset Management, SAS (French : Société par Actions Simpliﬁée)with a capital of 1 086 262 605 €AMF approved Portfolio Management Company- GP number 04000036
Corporate address: 90, Boulevard Pasteur - 75015 Paris- France 437 574 452 RCS Paris
This material is solely for the attention of “professional” investors.

AMUNDI ACTIONS EURO ISR - I
125 Stewardship Report 2021

October 2022

FACTSHEET
31/10/2020

EQUITY ■Focus on Environmental, Social and Governance key performance indicators
In addition to the overall ESG assessment of the portfolio and the E, S and G dimensions, the manager uses impact indicators to assess the ESG quality of his portfolio. Four representative
indicators of Environment, Social, Human Rights and Governance have been identiﬁed. The manager's minimum objective is to deliver a quality score higher than that of the index* on at least
two of the indicators..

Environnement¹

Social²

Carbon footprint per euro million of sales

Managers’ Diversity
40 %Total carbon portfolio footprint (Portfolio/Index) : 261 / 278
300

200

100

0

Scope 3*
Scope 2
Scope 1

72

69

42

34

164

30.37 %

Portfolio

Benchmark

10 %

0%

This indicator measures the average emissions in metric tonnes of carbon equivalent per unitof a company's revenue (€ million of sales). This is an indicator of the carbon intensity of thevalue chain of the companies in the portfolio.
* ﬁrst-tier suppliers only
Coverage rate (Portfolio/Benchmark) :97.93%

96.72%

Gouvernance³

Women Managers

Portfolio

BenchmarkAverage percentage of women managers%Rated/Rateable - Women Managers

86.83%

85.65%

Human Rights Compliance⁴
Decent working conditions and freedom of association

Board Independence Percentage

150 %

100 %
72.90 %

100 %

71.72 %

50 %99.31 %

98 %

50 %

25 %
0%

31.32 %

20 %

158

75 %

30 %

0%

Portfolio

BenchmarkThe average percentage of directors that meet the designated criteria for independence.
%Rated/Rateable - Independent board members

Human Rights Policy

Portfolio

Independent Board Members

98.49%

98.31%

Benchmark

Percentage of companies with policies that exclude forced or obligatory child labor or thatguarantee freedom of association, applied universally regardless of local laws.
%Rated/Rateable - Human Rights Policy

98.49%

98.31%

Sources and definitions
At 12/31/2019 the impact indicators reported underwent the following changes:
1. Environmental indicator Unchanged: Carbon intensity This data is provided by Trucost, This corresponds to companies’ annual greenhouse gas emissions expressed in metric tons ofcarbon dioxide equivalent. (CO2e). It covers the six greenhouse gases identiﬁed in the Kyoto Protocol with emissions converted into global warming potential (GWP) in CO2 equivalent.
Deﬁnition of scopes:- Scope 1: All direct GHG emissions from sources that are owned or controlled by a company.
- Scope 2: All indirect GHG emissions arising from the purchase or production of electricity, steam or heat.
- Scope 3: All other indirect GHG emissions, upstream and downstream in the value chain. For reasons of data robustness, in this reporting we have chosen to use only part of scope 3:
upstream emissions linked to ﬁrst-tier suppliers. First-tier suppliers are those with which the company has special relations and can inﬂuence directly.
2. Social Indicator Previous indicator: average percentage of women Board members New indicator as from 12/31/2019: average percentage of women managers This indicator gives amore global measure of the advancement of women within the company. Data provider: Reﬁnitiv
3. Governance Indicator Unchanged: average percentage of independent directors on the Board of Directors. Change of data provider as from 12/31/2019: Reﬁnitiv
4. Human Rights Compliance Indicator Previous indicator: average percentage of employees represented in collective bargaining. New indicator as from 12/31/2019: percentage ofcompanies with policies that exclude forced or obligatory child labor or that guarantee freedom of association and which are applied universally regardless of local laws. This indicator enables
better assessment of fundamental human rights issues. Data provider: Reﬁnitiv*It is nonetheless possible that this target may occasionally not be achieved.

Climate related reporting

Carbon Emissions

We have also developed carbon exposure and –■ www.amundi.com
Carbon emissions per EUR M invested
impact measurement tools. Amundi provides – Carbon emissions per EUR M of revenue
This material is solely for the attention of “professional” investors.
standard and custom reporting which can– Sector-based breakdown of carbon
include the following indicators:
emissions (as a %)– Geographical breakdown of carbon emissions(as a %)– Carbon reserves per EUR M invested

126 Stewardship Report 2021

October 2022

Carbon Reserves

Green Bond Impact– Carbon reserves per EUR M invested– Avoided emissions per EUR 1 million invested
per Year– Carbon reserves assessment coverage– Sources and definitions– Breakdown of avoided emissions per bond(in tCO2e per MEUR )Climate Risks & Opportunities– Portfolio use of proceeds breakdown by
project category– Physical risks– Portfolio use of proceeds’ geographic
breakdown– Transition risks– Other climate-related indicators (energy
transition score, 2°C alignment, etc.)– Portfolio ESG rating breakdown

Sample reports
Carbon footprint per euro million inv es ted

Carbon footprint per euro million of s ales

150

300
Scope 3*
Scope 2
Scope 1

41
100

Scope 3*
Scope 2
Scope 1

62
200

40

20
39
54
16

50

100

78

28

169

44
80
0
Portfolio0

BenchmarkPortfolio

BenchmarkBenchmark : MSCI WORLD
This indicator measures the portfolio’s carbon emissions in metric tonnes of carbon
equivalent (tCO2e) per euro million invested. This is an indicator of the emissions generated
by investment in this portfolio.

This indicator measures the average emissions in metric tonnes of carbon equivalent per unitof a company's revenue (€ million of sales). This is an indicator of the carbon intensity of thevalue chain of the companies in the portfolio.

* first-tier suppliers only

* first-tier suppliers only

S ectoral contribution to carbon emis s ions

Geog raphical contribution to carbon emis s ions
80%

40%

30%

60%

20%
40%
10%
20%

nd

a

er
la

ad

itz
Sw

al
ia
tr

C
an

in
K
d
te

us

an
m
U

ni

A

y

gd
om

s
nd

er

rla

N

et
he

G

an

ce

er
Fr

n

O
th

pa

es
at
St
d
U
ni
te

Ja

es

e

til
iti
U

R

ea

le

st

at

n

s

Te
l

ec

om

m
un

ic

er
at
M

at
io

ia
l

gy

s

er

le
st

er
m

su
on
C

En

s
ia
l

ap

tr

ca

du
s
In

lth
H
ea

on

su

re

ry

gy

na

re
di
sc

er
m

at
m

0%

C

fo
r
In

tio

no
ch

io
n

Te

Fi

na

nc

lo

ia
l

s

0%

Portfolio weightContribution to carbon emissions

This chart compares the weight of each sector relative to its contribution to the portfolio's
carbon emissions.

Portfolio weightContribution to carbon emissions

This chart compares the weight of each country relative to its contribution to the portfolio's
carbon emissions.

127

Green bonds are ﬁxed income instruments for which theproceeds are speciﬁcally designated for projects with clearlydeﬁned environmental beneﬁts. Eligible projects include, but
are not limited to, renewable energy, energy eﬃciency
Stewardship
Report 2021
(including eﬃcient buildings), sustainable waste
management, sustainable land use, biodiversity
conservation, clean transportation and clean water. The
issuer should outline the decision-making process it follows
to determine the eligibility of an individual investment in thelegal documentation for the security:
1) Use of proceeds2) Project evaluation and selection3) Management of proceeds4) Reporting

Avoided emissions :“Estimate of emissions that would have been released if aparticular action or intervention had not taken place. For
example, the use of insulation in premises might reduce theconsumption of gas to heat the building with theconsequential reduction of GHG emissions from the property.
In order to determine the level of emissions avoided throughthe use of certain goods or services, it is necessary ﬁrst to
establish what the level of emissions would have been had
the goods or services not been used. This level is known as abaseline level. The avoided emissions are quantiﬁed byreference to the diﬀerence between the baseline level andlevel of GHG emissions achieved through the use of thegoods or services.”**Source : CDP

The criteria are extra-ﬁnancial criteria used to assess theEnvironmental, Social and Governance practices ofcompanies, states or local authorities:

October 2022“E” for Environment (energy and gas consumption levels,
water and waste management, etc.).
“S” for Social/Society (respect for human rights, health andsafety in the workplace, etc.).
“G” for Governance (independence of board of directors,
respect for shareholders’ rights, etc.)
Rating scale from A (best score) to G (worst score)

Impact metric :Tons of CO₂ equivalent (tCO₂e) per 1Mn invested (in portfolio
currency).

Impact Reporting
Avoided emissions *Green Bonds WeighttCO2e331.98

Avoided emissions per €1Mn invested per Year* Calculation limited to green bond portfolio, based on available data

Breakdown of avoided emissions per bondWeight in portfolio
91.49%

Green Bonds

Portfolio use of proceeds breakdown by project category
100 %

200
176

Energy Eﬃciency (EE)

11.49 %

Renewable Energy (RE)11.68 %

82 %
75 %

150

Mix RE & EE

71.51 %

100

50 %

50

25 %

Weight in portfolio

0%

Renewable Energy :More than 70% of the green bond proceeds were allocated to RE
projects
Energy Efficiency : More than 70% of the green bond proceeds were allocated to EE projects
Mix : More than 70% of the green bond proceeds were allocated to RE & EE projects
combined
Other : Less than 70% of the green bond proceeds were allocated to RE & EE projects
combined and more than 50% of proceeds were allocated to other types of projects (water,
waste, etc.)

Other

0.83 %
0%

0

0-500

8 3%

10 5 %

6 4%

3 1%

500-1000

1000-2000

2000-4000>4000

Nb Issuers

Weight in portfolio

expressed in tCO₂e per million (in portfolio currency)

Portfolio use of proceeds’ geographic breakdown
3.14 %

6.97 %

20 %40 %3.83 %

2.78%

AB

52.74%

C

21.36%
31.62 %
46.98 %

Social Impact reporting

GlobalNorth America

F

0%

G
not rated

Amundi Asset Management, SAS (French : Société par Actions Simpliﬁée)with a capital of 1 086 262 605 €AMF approved Portfolio Management Company- GP number 04000036
Corporate address: 91-93, Boulevard Pasteur - 75015 Paris- France 437 574 452 RCS Paris
This material is solely for the attention of “professional” investors.

Amundi has developed a proprietary impact
measurement methodology for social impact
funds. Impact indicators include:– Number of jobs created or maintained– Number of people housed– Number of beneficiaries of healthcare
services– Number of people trained

E

0%

3.26%

C+

D

2.55%

Europe80 %Portfolio ESG rating breakdown

2.97 %

17.31%

Asia
Emerging
Under Review

60 %– Number of farmers funded– Number of cases of over-indebtedness
prevented– Number of tons of waste recycled– Number of hectares of farmland preserved– Number of enterprises created or supported
by microfinancing– Reporting Capabilities

128 Stewardship Report 2021

October 2022

Delivery against the expectations of other stewardship codes
EFAMA

UK

Amundireport#Principles#

Principles

1

Asset managers should have an
engagement policy available to the
public on whether, and if so how,they exercise their stewardship
responsibilities.

1

Signatories’ purpose, investment
beliefs, strategy, and culture
enable stewardship that creates
long-term value for clientsand beneficiaries leading tosustainable benefits for the
economy, the environment andsociety.

52Signatories’ governance,
resources and incentives support
stewardship.

12

2

Asset managers should monitor theirinvestee companies, in accordancewith their engagement policy.

7

Signatories systematicallyintegrate stewardship andinvestment, including material
ESG issues, and climate change,
to fulfil their responsibilities.

48

3

Asset managers should establish clear
guidelines on when and how they will
escalate engagement with investee
companies to protect and enhancevalue of their clients’ investments.

9

Signatories engage with issuers
to maintain or enhance the valueof assets.

67

4

Asset managers should consider
acting with other investors, whereappropriate, having due regard to
applicable rules on acting in concert.

10

Signatories, where necessary,participate in collaborative
engagement to influence issuers

92

5

Asset managers should consider
acting with other investors, whereappropriate, having due regard to
applicable rules on acting in concert.

12

Signatories actively exercise theirrights and responsibilities.

112

6

Asset managers should disclose theimplementation and results of theirstewardship and voting activities

6

Signatories take account ofclient and beneficiary needs andcommunicate the activities andoutcomes of their stewardshipand investment to them.

41

129 Stewardship Report 2021

Australia

October 2022

UK

Amundireport#Principles#

Principles

1

Organisational and investment
approach1

Signatories’ purpose, investment
beliefs, strategy, and culture
enable stewardship that creates
long-term value for clientsand beneficiaries leading tosustainable benefits for the
economy, the environment andsociety.

5

2Internal governance2Signatories’ governance,
resources and incentives support
stewardship.

12

3

Asset stewardship

7

Signatories systematicallyintegrate stewardship andinvestment, including material
ESG issues, and climate change,
to fulfil their responsibilities.

48

9Signatories engage with issuers
to maintain or enhance the valueof assets.

67

12

Signatories actively exercise theirrights and responsibilities.

112

130 Stewardship Report 2021

CanadaOctober 2022

UK

Amundireport#Principles#

Principles

1

Develop an approach to stewardship

1

Signatories’ purpose, investment
beliefs, strategy, and culture
enable stewardship that creates
long-term value for clientsand beneficiaries leading tosustainable benefits for the
economy, the environment andsociety.

5

2

Monitor companies.

7

Signatories systematicallyintegrate stewardship andinvestment, including material
ESG issues, and climate change,
to fulfil their responsibilities.

48

3

Monitor companies.

12

Signatories actively exercise theirrights and responsibilities.

112

4

Engage with companies.

9

Signatories engage with issuers
to maintain or enhance the valueof assets.

67

5

Collaborate with other institutional
investors.

10

Signatories, where necessary,participate in collaborative
engagement to influence issuers

92

6

Collaborate with other institutional
investors.

7

Collaborate with other institutional
investors.

2

Signatories’ governance,
resources and incentives support
stewardship.

12

7

Signatories systematicallyintegrate stewardship andinvestment, including material
ESG issues, and climate change,
to fulfil their responsibilities.

48

131 Stewardship Report 2021

Italy

October 2022

UK

Amundireport#Principles#

Principles

1

IMCs should have a documented policy
available to the public on whether, andif so how, they exercise their ownership
responsibilities

1

1. Signatories’ purpose,
investment beliefs, strategy,
and culture enable stewardshipthat creates long-term value forclients and beneficiaries leading
to sustainable benefits for the
economy, the environment andsociety.

52

2. Signatories’ governance,
resources and incentives support
stewardship.

12

2

IMCs should monitor their investee
companies

7

Signatories systematicallyintegrate stewardship andinvestment, including material
ESG issues, and climate change,
to fulfil their responsibilities.

48

3

IMCs should establish clear guidelines
on when and how they will intervenewith investee companies to protect
and enhance value

9

Signatories engage with issuers
to maintain or enhance the valueof assets.

67

4

IMCs should consider cooperating withother investors, where appropriate,having due regard to applicable ruleson acting in concert.

10

Signatories, where necessary,participate in collaborative
engagement to influence issuers

92

5

IMCs should exercise their voting
rights in a considered way

12

Signatories actively exercise theirrights and responsibilities.

112

6

IMCs should report on their exerciseof ownership rights and voting
activities and have a policy on external
governance disclosure

6

Signatories take account ofclient and beneficiary needs andcommunicate the activities andoutcomes of their stewardshipand investment to them.

41

132 Stewardship Report 2021

Japan

October 2022

UK

Amundireport#Principles#

Principles

1

Institutional investors should have aclear policy on how they fulfil theirstewardship responsibilities, andpublicly disclose it.

1

Signatories’ purpose, investment
beliefs, strategy, and culture
enable stewardship that creates
long-term value for clientsand beneficiaries leading tosustainable benefits for the
economy, the environment andsociety.

52Institutional investors should havea clear policy on how they manage
conflicts of interest in fulfilling theirstewardship responsibilities andpublicly disclose it.

3

Signatories manage conflicts ofinterest to put the best interestsof clients and beneficiaries first25

3Institutional investors should monitor
investee companies so that they canappropriately fulfil their stewardship
responsibilities with an orientation
towards the sustainable growthof the companies.Institutional
investors should seek to arrive atan understanding in common withinvestee companies and work tosolve problems through constructive
engagement with investee companies.

7

Signatories systematicallyintegrate stewardship andinvestment, including material
ESG issues, and climate change,
to fulfil their responsibilities.

48

4

Institutional investors should seek toarrive at an understanding in common
with investee companies and work tosolve problems through constructive
engagement with investee companies.

9

Signatories engage with issuers
to maintain or enhance the valueof assets.

67

5

Institutional investors should have aclear policy on voting and disclosureof voting activity. The policy on
voting should not be comprised
only of a mechanical checklist; itshould be designed to contribute to
the sustainable growth of investee
companies.

12

Signatories actively exercise theirrights and responsibilities.

112

6Institutional investors in principle
should report periodically on how they
fulfil their stewardship responsibilities,
including their voting responsibilities,
to their clients and beneficiaries

641

133 Stewardship Report 2021

October 2022

7

To contribute positively to thesustainable growth of investee
companies, institutional investors
should develop skills and resources
needed to appropriately engage
with the companies and to makeproper judgments in fulfilling theirstewardship activities based on indepth knowledge of the investee
companies and their businessenvironment and consideration ofsustainability consistent with theirinvestment management strategies.

2

Signatories’ governance,
resources and incentives support
stewardship.

128Service providers for institutional
investors should endeavour tocontribute to the enhancement of
the functions of the entire investment
chain by appropriately providing
services for institutional investors tofulfil their stewardship responsibilities.

8

Signatories monitor and hold toaccount managers and/or service
providers.

64134 Stewardship Report 2021

October 2022

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 October 2022.

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.