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Stewardship Report 2022

Stewardship Report2022
October 2023

October 2023

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Stewardship Report 2022

October 2023

PrefaceThat is why we consider that integrating ESG risks
and opportunities in our investment decisions,engaging with companies on ESG issues, andcarrying out voting activities are drivers of longterm value for our clients’ portfolios. Promoting
a transition to a more sustainable, inclusive lowcarbon economy while limiting the negative
impacts or even creating positive impact on end
savers and pensioners requires orderly transitionand coherent actions from governments,
costumers, companies and the financial markets.

Stewardship is a key pillarof Amundi’s responsible
investment strategy
In a complex and uncertain market due to therecent geopolitical events and repetitive climate
extreme events, we stand firm in our convictionthat responsible investment delivers long-termsustainable value to our clients. Addressing
climate change and biodiversity loss while
ensuring that the transition to a low-carbon
economy is socially acceptable requires a realindustrial revolution that can only be achieved if
key players – governments, businesses and thewider financial system – are aligned. Governments
must redefine public, industrial and fiscal policies
and coherent regulations; businesses must
develop the necessary technological solutions,and financial actors must support companies by
allocating the capital required to achieve theseobjectives.

Stewardship is a key pillar of Amundi’s
responsible investment strategy. We believethat active dialogue with our investees topositively influence their behaviors and activities
will enable us to participate in delivering real
impacts and outcomes as well as preserving
long-term economic capital. By 2025, Amundi
has committed to engage an additional 1,000
companies on their climate strategy compared
to 2021. In 2022, we actively engaged with anadditional 418 companies. At the same time, ourengagement efforts exceed the climate issues as
we see the interdependencies between different
sustainability factors. We have accelerated
engagement efforts in different dimension
including natural capital and social cohesion,
with 2,115 companies engaged (compared to
1,364 in 2021) and 10,208 General Assemblies
voted.
This report is organised according to the twelve
principles of the UK Stewardship Code andhighlight Amundi’s many efforts to integrate
ESG factors into investment processes andour engagement with economic actors acrossindustries.

Jean-Jacques Barbéris
Head of Institutional andCorporate Clients Division
& ESG

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Contents
PREFACE..........................................................................................................................................................................................2
PRINCIPLE 1: Signatories’ purpose, investment beliefs, strategy, and culture enable stewardshipthat creates long-term value for clients and beneficiaries leading to sustainable benefits
for the economy, the environment and society......................................................................................................... 4
PRINCIPLE 2: Signatories’ governance, resources and incentives support stewardship....................13
PRINCIPLE 3: Signatories manage conflicts of interest to put the best interests of clientsand beneficiaries first............................................................................................................................................................25
PRINCIPLE 4: Signatories identify and respond to market-wide and systemic risks
to promote a well-functioning financial system..................................................................................................... 30
PRINCIPLE 5: Signatories review their policies, assure their processes and assess
the effectiveness of their activities................................................................................................................................43
PRINCIPLE 6: Signatories take account of client and beneficiary needs andcommunicate the activities and outcomes of their stewardship and investment to them...............47
PRINCIPLE 7: Signatories systematically integrate stewardship and investment,
including material environmental, social and governance issues, and climate change,
to fulfil their responsibilities..............................................................................................................................................54
PRINCIPLE 8: Signatories monitor and hold to account managers and/or service providers........ 75
PRINCIPLE 9: Signatories engage with issuers to maintain or enhance the value of assets...........77
PRINCIPLE 10: Signatories, where necessary, participate in collaborative engagement
to influence issuers................................................................................................................................................................. 113
PRINCIPLE 11: Signatories, where necessary, escalate stewardship activities
to influence issuers................................................................................................................................................................130
PRINCIPLE 12: Signatories actively exercise their rights and responsibilities....................................... 136
Appendix....................................................................................................................................................................................148

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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. About Amundi: our culture and values _______
Amundi is a leading European asset manager with €1,904 billion managed on behalf of clientsas of 31 December 2022. Amundi’s mission is to be a trusted partner that acts every day in theinterest of our 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 1,500 direct institutional andcorporate clients.

a. Our raison d’être
At Amundi, our raison d’être is to be a trusted
partner working every day in the interest ofclients and society. Being a trusted partner
means:

clients is underpinned by our unique researchcapabilities, our proven track record in asset
management, as well as our high standards ofservice and technological tools.

Being attentive to our clients’ needs
Trust cannot be taken for granted, it must be
earned every day by delivering concrete results.
This is the guiding principle we have embodied
since our founding in 2010, and which has led
us to develop savings and investment solutions
that meet our clients’ expectations. We offer all
our clients, whether they are banking networks,
third-party distributors, institutional investors or
corporates, a full range of investment solutions
thanks to our six investment platforms operating
across all financial markets.

Being a responsible investor
Responsible investment is one of Amundi’s
cornerstones. We have always believed thatcompanies and financial actors have a responsibility
to tackle today’s major challenges, especiallyregarding the environmental transition and social
inclusion. We believe that taking these issues into
account makes it possible to create value in thelong term. That is why we integrate both financial
and non-financial analysis into our investment
decisions.

Being a long-term partner
Together with our 5,400 employees based in 35
countries, we believe that our relationship withclients should be based on trust. We provide
them with support on a daily basis to build alasting relationship based on sound advice,
long-term performance and a commitment tosocial responsibility. The work we do for ourAmundi is 70% owned by Crédit Agricole (CA),one of France’s largest bank and insurer. CA wasfounded by French farmers as a cooperative anda mutual financial institution more than a century
ago. We are proud of this heritage, which makes
it natural for Amundi to think first of clients’ bestinterests and to be responsive to social needs andthe environment.

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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 has been one of the four founding
pillars of Amundi since 2010, and it continues
to be a key component of our strategy. This

October 2023

commitment is reflected in our management
process, the solutions range Amundi hasdeveloped and the advisory capabilities wedeploy to help clients define and implement
their own approach.

B. Our culture
At Amundi we are proud of our rich corporate
culture, with four fundamental values at its
core: courage, team spirit, entrepreneurship andsolidarity.
Living our values
These values are both a reflection of and astructure to support the responsible investment
culture at Amundi. They underpin our investment
processes and inform our ambitions for the
future. We are constantly seeking to improveand enhance our processes, through learningfrom each other and the wider investmentcommunity. We also set ever more ambitious
goals for ourselves to live up to and keep us
accountable to these beliefs and values.

For example, as part of our “Ambition 2025” plan,
we are introducing measures such as adding
societal and environmental criteria to determine
variable compensation for senior executives.
More detail on “Ambition 2025” can be foundin later in this Principle. We remain committed
to providing educational and development
opportunities to all employees at Amundi, bothto continue to their professional development
and also ensure that we stay at the forefront ofdevelopments in our industry in order to be best
prepared to deliver for our clients. More detailon the training offered in 2022 can be found in
Principle 2.

C. Diversity, Equity and Inclusion (DE&I) at Amundi
Fostering a diverse and inclusive workplace
is an essential component of maintaining thisculture. This is predicated on our belief thatinternal cohesion and a sense of belonging area factor of performance, as well as our duty as a
responsible employer.
The DE&I policy applies to all Amundi
employees. It complies with the national laws
and regulations in the jurisdictions in which we
operate. The policy seeks to:– Promote an inclusive culture and raiseawareness among all employees by
combating sub-conscious prejudices andstereotypes, collecting and disseminating
good practice and asking for managers’ help
in disseminating this culture;– Ensure equity in key HR processes:
recruitment, compensation, and merit-based
career promotion and review;– Facilitate the development of global
programmes to speed up priority Inclusion
and Diversity issues and, at the same time,
the provision of support for local initiatives

to better take geographical specificities into
account.
With a presence in 35 countries and with morethan 80 nationalities, Amundi nurtures andpromotes cultural diversity. Amundi firmly
believes that the cultural wealth of its teams,
united around a common goal, strategy andvalues (courage, team spirit, entrepreneurship,solidarity) is a key factor in its success. Whilecommon principles guide Amundi entities
around the world, particular attention is paid
to consideration of local social and societal
realities. Consequently, countries can build on
the diversity, equality and inclusion policy andare responsible for its local implementation. A
global HR Management Committee, chairedby the Amundi Group HR Director, bringing
together all the HR Directors of the Amundi
entities, meets every week to ensure that specificlocal circumstances are taken into account andto encourage the exchange of best practices.

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Illustration 1: Gender equality
Gender equality is a fundamental component of diversity. Promoting gender diversity means
creating an open, responsible corporate culture that fosters internal cohesion and progress.
This commitment is underscored by concrete actions on equal pay for men and women,
support for women in positions of responsibility, training, work/life balance and, more broadly,
raising everyone’s awareness of the challenges of gender equality.

Amundi gender diversity as at December 31st 2022
Women

41.2%

Men

58.8%

13.4% of executive managers are women
36.7% of Executive Committee members
are women
We are committed to increasing female
representation on governing bodies, witha target of 35% women in Amundi’s top
management by 2025.

Gender Equality Index
Amundi first assessed a gender equality index score in 2019, a mandatory indicator defined by
the French Labour Code, which has made consistent progress since that date. In 2022 we scored85 out of a maximum of 100 points, up one point from last year, reflecting an improvementin the gender pay gap. Scores are calculated using the following indicators: equality of rates
of individual wage increases (excluding promotions), promotion rate, proportion of female
employees whose wages were increased after returning from maternity leave.
Initiatives and networks to develop the presence of women at Amundi and the wider industry– Women in Finance Charter – Amundi signed the charter in 2019 to help build a morebalanced and fair industry, in particular gender balance in positions of responsibility acrossfinancial services firms– Women in Investing (WIN) – Amundi US maintains an annual participation in the Womenin Investing Conferences, hosted by Cornell University’s SC Johnson College, designed toeducate female MBA students about careers in investment management– Women & Science chair with the university of Paris-Dauphine – in 2022 Amundi became apartner of the Women & Science chair, challenged with promoting the place of women inscience– 30% club France investor group – since 2020 Amundi has been a committed participant topromote gender diversity within the governing bodies of SBF 120 companies– Amundi Women Network - Amundi’s gender diversity network was created in 2017. It
now has over 566 members in France, including 170 men (30%) and is expanding in
Ireland, Germany, Japan and the US. Amundi Women Network is a member of Cercle
Potentielles, the representative body of the seven gender diversity networks of the Crédit
Agricole Group, which in turn is a member of the Financi’Elles network whose mission is
to contribute to improving, and above all accelerating, women’s access to the top levels ofmanagement in the finance sector.
Please note that according to French regulations, statistics on ethnic or religious diversity are
not available.

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2. Responsible investing at Amundi ___________
a. What acting as a responsible investor means to Amundi
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.

As a responsible asset manager, we acknowledge
that it is our responsibility to support efforts toaddress systemic problems and to effectively
allocate capital for the future. As a major
shareholder via the funds and mandates wemanage on behalf of its clients, we have both the
responsibility and the opportunity to encourage
and accelerate the transition of companies
towards more sustainable models. Since 2010,
we have been committed to incorporating
environmental, social and governance (ESG)
factors into our investment processes, as well as
supporting a sustainable transition through an
ambitious engagement policy, the developmentof sustainable capital markets, and themobilisation of capital on a global scale.

Illustration 2: Sounding out our clients to serve their best interests
In 2022, we continued our efforts in ensuring a correct understanding of institutional clients’needs to be able to respond to them in an adequate and timely way.
The annual Amundi-CREATE survey of European pension funds, launched in 2014, wasrenewed. Each year, a main topic of interest is chosen for the survey, depending on the market
environment and the priorities of the pension funds. The 2022 survey was conducted among
more than 150 pension funds. It covers the challenges faced by pension schemes following
the recent surge in inflation in Western economies, its impact on their asset allocation and theevolution of ESG investment in the pension universe. The results of the report are used to adapt
Amundi’s product and service offering to best meet pension funds’ evolving requirements.

B. Our strategy: From philosophy to actions
Amundi’s approach to responsible investing
rests on three main convictions:– Economic and financial players bear asocietal responsibility;– The integration of ESG considerations/factors in investment choices is a source oflong-term performance;– ESG will be a growth driver for Amundi,worldwide.

Our commitment and convictions in ourinvestment management activities is reflectedin the development of our investment solutions
range, and the advisory capabilities andservices we deploy to support clients define andimplement their own approach.

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Our core investment beliefs are founded on the understanding that long-term and sustainablesuccess lies in collective effort and sound processes. Those beliefs are:
“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

“Only a prepared mind canreact”
Investment requires theadaptation of widelyaccepted assumptions
and the ability to processeconomical, geopoliticaland sustainability factors tonavigate increasingly frequent
markets disruptions andparadigm changes“Value creation goes beyond
performance ”
Being asset owners
and managers brings
responsibilities

We embrace the concept of “double materiality”,
around which we build our proprietary ESG
analysis and rating methodology. This meansthat our ESG analysis aims to only assess theway ESG factors can materially impact thevalue of companies, but also how companies
can impact the environment, and social mattersor human rights. This centralised methodology
promotes a consistent approach to responsible
investment across the organisation, in line with
Amundi’s values and priorities.
The Responsible Investment strategy is
integrated across our asset management
activities through policies governing asset
exclusion, ESG integration into investment
process, and voting, activity as well as throughthe range of dedicated responsible solutions
and services.

“Investing for the long term is
an advantage”
Investing over the long termallows us to capture sourcesof growth 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 crossfertilisation are sources ofadded value

Dedicated resources make the deployment of
our Responsible Investment strategy possible.
They ensure the principles and standards acrossAmundi responsible investment solutions’ range
are consistent, and help customise solutions
and services to meet the ESG preferences ofour clients. (More information can be foundin Principle 2). Our proprietary ESG rating
methodology and fundamental qualitative
ESG research capabilities are key pillars of
our strategy. Our commitment to addressing
challenges in ESG and climate change is reflectedin our ambitious action plans, the 2018 – 2021
ESG plan achieved in 2021 and the “Ambition
2025” plan, which is currently underway.

Illustration 3: 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

2017

2019
Amundi launches a fullrange of SRI equity
and bond ETFs

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

2018

Innovation in
Sustainable FinancePartnerships with the
EIB2 AND the AIIB

• Amundi joins
the Finance for
Biodiversity Pledge• Joining the Net
Zero Asset Managers
initiative

2021

2022

€800 billion in
Responsible
Investment assets

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➜ Progress in 2022
– Amundi created a new position, Chief Sustainable Transformation Officer, tasked withmobilising and co-ordinating the company's various departments to support an accelerated
transformation within the Group's business lines. We have made significant progress on the
Ambition 2025 plan, more detail can be found in Illustration 6 below– The Board strengthened the company's governance by appointing a Deputy Chief
Executive Officer– Amundi joined the GISD Alliance and commits with the UN’s efforts to close the investment
gap in sustainable development– Elodie Laugel, Amundi’s Chief Responsible Investment Officer, was selected to be part of
the European Commission's high level expert group on scaling up sustainable finance in low
and middle income countries– NZAM initiative disclosed Amundi’s initial Net Zero target for 2025 of 18% of its AUM, to becomposed of funds and mandates with explicit and binding Net Zero alignment objectives

Illustration 4: ALTO Sustainability
To better contribute to the empowerment of its clients on climate issues, and as part of our ESG“Ambition 2025” plan, Amundi announced the launch of ALTO Sustainability, a technologicalanalysis and decision-making solution for investors on environmental and societal issues.
ALTO Sustainability is an innovative modular solution that provides clients with additional
flexibility allows institutional investors and asset managers to easily integrate sustainable
investment indicators from leading data providers into the ALTO* platform to align theirinvestment decisions with their sustainable investment objectives. By combining Amundi’s
renowned expertise in terms of sustainable investment and its technological know-how, ALTO*
Sustainability allows investors to benefit from a comprehensive view of issuers’ characteristics,
integrating both financial and non-financial considerations.
It will allow users to:– Build customised scores at issuer and/or portfolio level;– Integrate their own ESG data and analysis into ALTO* Investment, an integrated front-toback and back-to-front portfolio management platform offering a 360° view of portfolios.
– Integrate third party ESG data and have a dedicated workspace with separate access.

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Illustration 5: Client Training Campaign
In 2022 we continued with our client training campaign– 119 seminars, training sessions, and meetings took place for over 3,900 institutional clientsreaching 26,700 professional investors.
– 41 seminars, trainings, and meetings, were held with private banking clients and other
distributors, reaching 32,000 retail investors.

Illustration 6: ESG “Ambition 2025” plan – 2022 progress
Amundi’s “Ambition 2025” plan aims to increase its commitments to tackling climate change,
arguably the greatest challenge of our time, through the savings and investment solutions
offered to our clients, actions taken to assist businesses, and measures to align our employeeswith our new ambitions.
This ambition to deepen ESG integration throughout the whole asset management value chain
also reflects increasing ESG commitments by our clients across the world. This new three-yearplan comprises an ambitious set of goals to address their current and future needs.
The plan has three key objectives, containing a number of key goals to work towards theseobjectives. By 2025, Amundi commits to:
1. Strengthening our Responsible Investing savings offering for sustainable development1
a. 100% of actively managed funds will integrate assessment of the transition efforts of theirholdings, with the objective to achieve a better portfolio climate transition profile than theirrespective universe
2022 update: methodology for environmental transition assessment/rating is underdevelopmentb. Establish a broad “Net Zero” offering by developing new solutions targeting greenhousegas emission reduction objectives in line with attaining net Zero emissions by 2025.
2022 progress: four asset classes offer a minimum of one Net Zero Ambition solution
c. Expand impact investment solutions to €20 billion AUM through the launch of new
investment solutions targeting a positive environmental and social impact.
2022 progress: Impact Investment AUM increased to €8.7bn.
d. Enlarge responsible investing in passive management by expanding the ETF range toinclude 40% ESG ETFs
2022 progress: 27% of the ETF range is composed of ESG funds
e. Provide clients with access to cutting edge sustainability analytics through ALTO
Sustainability (Amundi Leading Technologies and Operations) a modular technology
solution that integrates a wide range of ESG & Climate analytics
2022 progress: the content of the first module of ALTO Sustainability has been developed.
2. Deepen the integration of ESG in our investment solutions
a. Broaden engagement efforts to +1,000 companies through the deployment of a climate
engagement plan
2022 update: our climate engagement plan has been extended to 418 new companies.
b. Divest from companies that conduct more that 30% of their business in unconventionalhydrocarbons by 2022
2022 update: Amundi has completed divestment from all such companies
1. All 2022 updates and figures are valid as of 31/12/2022

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3. Set objectives internally in line with our commitmentsa. Extensive integration of ESG criteria into Renumeration policy
From 2022 we have integrated ESG and CSR KPIs into the remuneration and performance
structures applicable to the CEO and the 200 most senior executives, sales and portfolio
managers
2022 update: ESG objectives were incorporated in the annual objectives of 99%2 of
portfolio managers and sales representatives and the implementation of the “Ambition
2025” plan accounted for 20% of the criteria supporting the performance share planawarded to 200 Amundi senior executives.
b. Reduction of Amundi’s operational emission by 30% per employee
By 2025 we target a 30% reduction in our GHG emissions per employee on Scope 1 & 2
emissions as well as in business travel2022 update: An action plan has been launched on greenhouse gas emissions related toenergy usage (scopes 1 and 2) and business travel (scope 3).
c. Present our climate strategy (Say on Climate) to shareholders during the 2022 annual
shareholder meeting.
2022 update: At the Annual General Meeting on 18 May 2022, the resolution was approvedby 97.72%.

C. Engagement & Voting, a key pillar of our strategy
Stewardship activity is central to Amundi’s
responsible investing philosophy, alongside thesystematic integration of ESG criteria in our
active investments. We believe that stewardshipand effective engagement play a key role inenabling a wide transition towards a sustainable,
inclusive low carbon economy. Amundi hasdeveloped an active programme of stewardship
activities through engagement and voting.
As a major shareholder via the funds andmandates we manage on behalf of our clients,
Amundi has a role to play in driving capital
towards the leading actors in ESG and in
influencing laggards to adapt and evolve theirstrategies to combat key issues. We recognisethat as part-owners of the companies in which
we invest that we have an obligation to influence
their strategies towards approaches that takeaccount of ESG issues more effectively. We seek
constructive dialogue to help drive change andto support those who are already delivering
positive results.

Our proactive engagement policy seeks to:– Contribute to the dissemination of bestpractice and drive a better integration ofsustainability in companies’ governance,
operations and business models.
– Trigger positive change concerning how
companies manage their impacts on specifictopics that are key drivers of the sustainable
future of our society and economy.
– Support companies in their transition towards
more sustainable, inclusive and low carbon
business models.
– Engage to push issuers to increase theirlevels of investment in Capex/R&D in highly
needed areas to facilitate this transition.
Our voting activity is an integrated arm of
our stewardship activities (More details on
this can be found in Principle 3). Insufficient
improvements following an active engagement
could trigger a negative vote. Engagements
are also triggered by our voting activity toencourage issuers and their boards to better
integrate sustainability and long-term views intheir company’s strategic planning.

2. At the time of the closing of the appraisal campaign (including setting 2023 objectives), not all managers andemployees were present

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Our voting policy makes best use of our duties
as part-owners of issuers and emphasises thefollowing needs:– For accountable, diversified & wellfunctioning boards,– For corporates’ governance and boards thatgrasp environmental and social challenges,– To ensure that boards and corporates areappropriately positioned and prepared tohandle the transition towards a sustainable,
inclusive low carbon economy.

October 2023

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.

➜ Progress in 2022
As part of our ESG Ambitions 2025 plan, Amundi launched a cycle of engagement on climate
issues in 2022 that will see an additional 1,000 companies enter into constructive dialogue with
us by 2025. Amundi specifically requests that businesses publish a detailed climate strategy
based on specific indicators and set out objectives for each carbon emission scope and on thecorresponding capital expenditure (investment plan). In 2022, Amundi engaged an additional
418 companies on the climate issue.
This engagement covers all environmental, social and governance issues. Beyond the specifictopic of climate change, in 2022, specific thematic commitments included the circular economy;
biodiversity, for which a specific report was published on our website; deforestation; ocean
protection; strategy for alignment with the Paris agreement; the just transition; human rights;
living wage; as well as fair distribution of added value within companies.

2022 Engagement at a glance:
Indicators
Engagement
policyVotingpolicy

Unit

2022

2021

2020

Number of issuers excluded

Number

954

833

617

Total number of companies engaged

Number

2,115

1,364

NA

Number of additionnal companies involvedin ongoing dialogue issues

Number

418

NA

NA

Number of resolutions subject to vote

Number

107,297

77,631

49,968

Number of General Meetings subject to vote

Number10,208

7,309

4,241

Level of support for climate shareholder resolutions

%

87

86

NA

Average opposition rate

%

21

20

20

More detail on our engagement & voting activities in 2022 can be found in Principle 9 to 12.

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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
Taking action as a responsible financial institution is an essential component of Amundi's
strategy, as such responsible management is integral to our governance. The responsibility toachieve the group’s ESG objectives lies with both the supervisory and management bodies, andis central to the way these governance bodies operate.
The responsible investment strategy is discussed at the highest levels and is governed by dedicatedcommittees reporting to the Board of Directors and the General Management Committee. These
governance bodies regularly interact with each other and with the various business lines working
on these issues, primarily via the Responsible Investment team.
See Principle 3 for more information on our relationship with Crédit Agricole and how we manage
conflicts of interest between the businesses.

Governance of ESG issues within Amundi
Board of Directors
Strategic and CST
Committee

Risk Management
Committee

Compensation Committee

Appointments Committee

Audit Committee

Chief Executive Officer (CEO)Head of Institutional & Corporate Clients and ESG

General Management
Committee

Chief Responsible Investment Officer (CRIO)

Executive Committee

ESG and Climate Strategy Committee
ESG Rating
Committee
Investment Committee

VotingCommittee
ESG Management Committee

Risk Committee

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A. Dedicated Responsible Investment Business Line
Amundi has a team dedicated to responsible
investment, under the supervision of JeanJacques Barbéris, an Executive Director of thefirm and Supervisor of ESG. This department is
positioned as an autonomous and independent
unit within the overall organisation, serving
the needs of institutional, distributor and retailclients as well as investment platforms.

General organisation and figures
The team is organised around five 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– The ESG Regulatory Strategy

Organisation and positioning of the Responsible Investment Team
Jean-Jacques Barberis
Executive Committee Member
and Head of Institutional Clients
Coverage & ESG

Hélène Nanty

Élodie Laugel

COO Office

Chief Responsible Investment
Officer

Florent Deixonne

Annie Chor Joyce

Head of ESG Regulatory
Strategy

Head of ESG USA

Tegwen 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

Olivier Melennec
Deputy Head ESG Research,
Engagement & Voting

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

ESG Research Team

Hélène Champollion MorelHead of Advocacy

Paris

Proprietary ESG analysis methodology,
ESG Engagement policy and ESG
Exclusion policy
Paris - London - Tokyo - Singapore
Edouard Dubois
Head of Voting team

Alice Sireyjol
Deputy Head of ESG development
Paris - Munich - Hong Kong Tokyo - Milan

Assess resolutions and Vote at AGMs,
Pre-AGM discussions with companies
Paris - London - Tokyo

The Responsible Investment team has an overall average experience in the ESG / CSR sector of six
years and is composed of 65% women.

Stewardship Report 2022

October 2023

Experience in the ESG / Corporate Social Responsibility industry of Responsible
Investment Team
20
16

16
14
Years

15

6

6

6

ESG Researchanalysts

Voting & Corporate
Governance analysts

ESG
Development &Advocacy

Max experience

The team has a wide range of experience andexpertise, with members across the teamholding dedicated relevant qualifications inareas including:– Natural Resources & Sustainable
development

5

ESG Method& Solutions

Average experience– Business and Human Rights– Climate Risks– TCFD training– Responsible Investment Analysis (PRI)– Bilan Carbone® Methodology Training– Sustainable Development Management(MOOC & CentraleSupelec)– ESG Investing (CFA)– Sustainable Finance (MOOC)

B. The ESG Research, Engagement and Voting team, the keystone ofstewardship exercise
Led by Caroline Le Meaux, the ESG Research,
Engagement and Voting team spans Paris,
London, Beijing, Singapore, and Tokyo. Sitting
within the Responsible Investment divisionat Amundi, the team is independent from theInvestment Management and Financial Analysis
teams ensuring the quality and independenceof the ESG analysis, while working in close
collaboration with portfolio management teams.
Through its stewardship activities, Amundi
is seeking to have a positive impact on theeconomy. We truly believe that active ownershipgenerally yields more robust outcomes thandivestment.
The ESG Research, Engagement and Voting
team currently comprises 25 dedicated ESG
research and engagement analysts and 8 Voting& Corporate Governance specialists globally that
contribute actively to our stewardship efforts. It
is split into two divisions:– The ESG Research team is responsible forinternal ESG content and organises ourengagement efforts. Each analyst specialises
in various sectors and themes and is theprimary person responsible for driving
ESG research and engagement strategies
internally on those sectors and topics. The
analysts meet, engage and maintain constantdialogue with companies to improve their
ESG practices and have the final say overthe ESG ratings of companies to ensure thatinternal 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 theimpact of those sectors on the sustainability
factors.

While ESG analysts work in close collaboration

16

Stewardship Report 2022

withresearch
analysts
andportfolio
management teams of the broader firm, their
independent status ensures the quality andthe objectivity of the ESG analysis that they
carry out.
– The Amundi Voting and Corporate
Governance team consists of specialists thatanalyse resolutions and organise ongoing
dialogue that Amundi wishes to have withcompanies pre- and post- Annual General
Meetings (AGMs), with the aim of better
understanding their strategy and pushingfor continuous improvement in practices.
These conversations are also an opportunity
to engage with issuers on practices that
foster progress. We recognise that individualcompany approaches take time to evolve,
and we look for progress and momentum asmuch as achievement. Our pre-AGM dialogue
with companies aims to encourage ongoing
improvement, which then informs our voting
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 voting
related tasks, and responsible for managing
the voting rights that have been delegated by
the funds and subsidiaries.

October 2023

is the in-house centre of ESG content expertisethat supports all of Amundi’s investment
platforms. The team members work actively
with fund managers and financial analysts tostrengthen ESG knowledge and expertise acrossthe whole company; including ESG trends or the
positioning of issuers.
The profiles of the ESG analysts are diverse andwe constantly strive to maintain a balance ofskills and backgrounds within the team. Hailingfrom seven different nations and operating
across five offices globally, their cumulative
work experience spans 10 countries. This richdiversity significantly enhances the quality of
our ESG research, contributing meaningfully tothe depth and breadth of our insights.
There is strong experience across the team in
analysis, both on the sell- and buy-sides, butalso a range of experience in audit, and ESG
and CSR consultancy, as well as direct industry
experience in a variety of businesses, from fashion
to insurance, construction and IT software. The
team’s industry specialties are shaped by thisrange of experience, giving us deep insight into
the operational challenges of business, whichenables more thoughtful understanding of theissues faced by the companies in which weinvest on clients’ behalf.

The ESG Research, Engagement & Voting team

The ESG Research, Engagement and Voting team is supported byfour other teams
ESG Method and Solutions team
The team of eight quantitative analysts
and financial engineers is led by Tegwen Le
Berthe and is responsible for maintaining anddeveloping Amundi’s proprietary ESG rating
system and ESG data management systems(which includes the selection of external data
providers to create ESG ratings). They help
analysts and portfolio managers integrate ESG
considerations into their investment decisions.
They also support business development teams
in creating innovative solutions by integrating
ESG data into financial products (ESG ratings,
climate data, impact indicators, controversiesetc.). They oversee the development andintegration of ESG tools into Amundi’s portfolio
management systems and the systems forproviding information to clients. They are also
responsible for implementing client-specific
ESG exclusion rules.
ESG Business Development & Advocacy team
Led by Timothée Jaulin with presence in Paris,
Munich, Tokyo and Hong Kong, the team of 14
is in charge of developing and promoting ESG
solutions tailored to the needs and challenges ofinvestors, and offering ESG advice and services
to all Amundi clients. It is also responsible formanaging communication campaigns on key
ESG issues with all stakeholders, centralisingcollaborative actions with sustainable financeinitiatives and developing training programmes
for our clients and employees.

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Stewardship Report 2022

ESG COO Office
Under the responsibility of Hélène Nanty, theteam coordinates the Responsible Investment
Department’s projects with the Group’s support
functions, produces business monitoring
dashboards (Business, Budget, IT, Audit,
Projects) and oversees major cross-functional
projects.
ESG Regulatory Strategy
This team led by Florent Deixonne is responsible
for ESG regulatory issues. It supports Amundi’s
development by anticipating the impact of
future ESG regulations, and contributes tothe financial sector’s work on the continuous
strengthening of the ESG investment framework
in all jurisdictions.
Interactions between ESG team and portfolio
managers team
The Responsible Investment Business Lineprovides ESG rating, assessment and scoring
methodologies as well as qualitative analysis. It
also provides research, support and knowledgetransfer to the investment hubs across the firm.
All team members collaborate with investment
professionals to help them integrate ESG into
their investment processes and expertise.
Periodically, the ESG Analysts meet with FundManagers to share their opinions on specificissuers. In addition, in a monthly basis, ESG
analysts organise training sessions on specificsectors or thematic. This session is a place toexchange and spread the ESG culture with

October 2023

Fund Managers and Product Specialists of
all Investment platforms. ESG teams also
communicate with all of Amundi’s team throughdifferent channels– Monthly newsletter: The ESG Business line
has launched a monthly newsletter thatis informing Amundi’s teams about the
Responsible Investment news
– Monthly ESG ratings update news: The ESG
Method Solutions team’s provides monthly
global statistics on corporate and sovereigns
ESG ratings (turnover no of rated issuers),
as well as ESG coverage stats on all major
equity and bond indexes in the monthly
news. Portfolio managers receive the news intheir inbox– ESG “Weekly picks and food for thought”:
The ESG Research team sends out weekly
information on ESG related topics which
has been developed for the use of portfolio
managers– Internal web conference: Internal Web
Conferences are proposed to all Amundi
staff in order to support them in acquiringknowledge on ESG topics
In addition, the investment team participates inthe ESG & Climate Strategy Committee and the
ESG Rating Committee (including methodology
validation, exclusion policy review, individual ESG
rating review), thereby ensuring coordination
between the teams in the implementation of theGroup’s responsible investment strategy.

➜ Our progress in 2022: Reinforcement plan continues
In 2022, the Responsible Investment department continued to grow following the reinforcement
plan implemented in 2021. The team increased from 40 members to 62, with investment into the
ESG Research team, the ESG Business Development team, Voting and Corporate Governanceteam and ESG method and solutions team.
2022 also saw the implementation of a dedicated role to cover ESG regulation.

18

Stewardship Report 2022

October 2023

C. Dedicated governance to monitor and manage the responsible
investment strategy
With the support of these teams, four
Responsible Investment steering committees
ensure the regular and structured follow up of all
work carried out by the Responsible Investment
team. They are regularly monitored by Amundi’s
CEO.
The ESG and Climate Strategic Committee
Chaired by Amundi’s CEO, this committee meetson a monthly basis with the responsibility to:– Steer, validate and monitor Amundi’s ESG
and climate strategy,– Validate major strategic changes to the
Responsible Investment policy,– Monitor the progress and achievement of the
Ambition 2025 plan, andThe ESG Rating Committee
Including senior managers from investment,
responsible investment and risk and compliancebusiness lines, and chaired by Amundi’s Chief
Responsible Investment Officer, this committee
meets on a monthly basis. The committee is
responsible for:– Defining Amundi’s ESG rating methodology,
systems, processes and resources andapproving any amendments,– Validating the criteria for and application of
exclusion and sector policies,– Reviewing and taking decisions regarding
ESG ratings on specific cases of exclusion,
based on due diligences done by the ESG
team, or in case of escalation, and– Developing Amundi’s ESG jurisprudence on
emerging issues.
The committee also deals with ESG topics related
to climate and the energy transition (such as ourcoal policy, carbon footprint methodology, ratingof issuers facing climate related controversies),and social and societal issues. Two Externalsenior experts are permanent guests to thiscommittee to participate in discussions.

Voting Committee
Chaired by Amundi’s Responsible Investment
Supervisor, this committee includes personnel
from the Responsible Investment team alongwith external advisers. They meet at least oncea month, with ad hoc meetings scheduled whenneeded, with responsibility for:– Supervising the consistent application ofAmundi’s voting policy and acting as anadviser for voting decisions on individual
cases– Reviewing and validating the following key
activities:- Principles of Amundi as an active andresponsible shareholder, and interaction withissuers,- 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, and- Ensuring alignment of voting activities withkey ESG engagement themes.

Two External senior experts are permanent
guests to this committee to participate indiscussions.
ESG Management Committee
This committee includes the senior leadershipof the Responsible Investment Team. This
committee meets on a weekly basis and 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,and– Promoting ESG across the business,addressing key client requests and business
opportunities.

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Stewardship Report 2022

October 2023

➜ Our progress in 2022
In 2022, we included additional participants for two of those committees– ESG rating committee: Addition of two permanent experts for US and real assets expertise– ESG and climate strategy committee: Addition of representatives for the following business
lines- Strategy, Finance and Control Division- French Partner Networks Division- Compliance- Sustainable Transformation

D. Sharing and fostering expertise across the businessTraining and education
The training around responsible investment thatis available to the wider Amundi business wasstrengthened in 2022 with the addition of a
"Responsible Investment Training" programme.
Delivered via an e-learning platform, the courses
have been jointly designed by the Responsible
Investment, Training and CSR teams incollaboration with the different business lines.
They include the fundamentals of responsible
investment along with Amundi’s strategy,
convictions and ambitions for Responsible
Investment by 2025, particularly the Climate
Strategy. Tailored modules are also available for
specific business lines to meet their particularneeds.
Particular attention is being paid to training
Amundi’ s senior executives so that they havethe knowledge required to ensure a robustand effective implementation of Amundi’s
responsible investment strategy. In addition to
training, employees also receive expert support(in particular the Responsible Investment team,“ESG champions”) to help them implement
good responsible investment practices. The“ESG champions” within the management
platforms serve as ambassadors of responsible
investment issues for their colleagues and are key
contributors to cross-functional projects related
to responsible investment (e.g. the definition of
the Sustainable Investment Framework).

As a part of the “Ambition 2025 plan”, Amundi
has set itself the goal of training 100% of its
employees in responsible investment by the endof 2023 and we are on track to achieve this.
A culture of teamwork and information sharing
ESG Research analysts, financial analysts andfund managers share the same research center,
where all research and engagement streams are
published. The calendar of all engagements arealso shared, enabling investment professionals
to join. Regarding engagement, ESG analysts
have developed engagement toolkits that
describe for different subjects the questions
to ask as well as the best practices. For a given
company under engagement, the questions
asked, the status of the engagement is recordedin this tool, enabling the financial analysts or thefund manager to understand the nature and thequality of the answer from the company.
Regarding investment decisions, Fund managers
have the final say, except if the company is
excluded from the investment universe. A
negative override of the ESG score in case of
escalation is a penalty, as average ESG scoreof portfolios have to be higher than that of thebenchmark.
More information on the integration of ESG andstewardship to the investment process can befound in Principle 7.

20 Stewardship Report 2022

October 2023

3. External research providers, an essential resource
A. Integrating external data in ESG analysis and rating work
Our ESG Research team leverages data fromexternal providers. The information received
covers ESG scores, ESG controversies, and other
ESG-related information. Our analysis draws on
this data to generate proprietary scores, ratingsand 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 andCO2 data.
We source inputs from specialist global
providers, each with its own methodology andinbuilt biases. By taking inputs from a rangeof sources and applying our own proprietary
analysis and approach we can gain a fuller

understanding of companies and provide ourinvestment teams with a fulsome picture andvaluable insights.
The use of such third-party data gives Amundi:– Greater overall coverage of issuers by
combining different footprints, as someproviders have better coverage of particularregions/ sectors/asset classes.
– A 360° view on critical ESG topics andrelevant issuer behaviour, as data providers
take different approaches to analyse aparticular criterion.
– Access to more frequent analysis updates,
as each data provider updates their analyses
according to different schedules.

We source data from 16 main providers:

16 main providers
Generalists

ClimateControversies / controversial weapons

Sovereigns

21

Stewardship Report 2022

October 2023

These data providers are selected according to a dedicated due-diligence process undertaken by
the ESG Method and Solutions team. We use these data sources to inform our proprietary ESG
analysis and ratings methodology.
More information on which can be found in Principle 7.

Illustration 7: Assessing companies’ performance on biodiversity
Biodiversity is an area of increased focus. Scientific knowledge led by IPBES is progressing fastand biodiversity-related regulations and initiatives such as the Task-Force on Nature Financial
Disclosure or the Global Biodiversity Framework, to name but a few, are being developed.
Biodiversity is by nature a very broad topic. The data to understand it fully remain scarce andthe biodiversity footprinting methodologies, which aim at giving a full picture of a company
impact on biodiversity, are still nascent. For this reason, and after conducting a data andmethodology review process, Amundi decided to analyse companies' biodiversity performancebased on a wide breadth of data.

Data TypeESG Rating

Data providers

Other risks– Vigeo

Biodiversity is a dedicated partof Amundi Company overall ESG
Rating– MSCI– Sustainalytics– Amundi ResearchControversies– MSCI– Sustainalytics

Biodiversity-related controversies
are assessed

Materiality– ENCORE

Materiality assessment of acompany impact and dependency
on biodiversity

Practices– MSCI

Raw data on water usage or
pollutants intensity to evaluate
companies practices– Trucost– Refinitiv
Policies– CDP– Refinitiv

Activities– MSCI– Trucost– Amundi Research

Biodiversity
footprint– CDP– Iceberg Data Lab

Biodiversity-related policies ofcompanies are assessed
Revenues of companies areanalysed to identify companies
with negative (pesticides
production, …) or positive(water treatment, …) impact on
biodiversity
While mainly based on modeleddata, biodiversity footprint
indicators are useful tounderstand the overall impact of acompany business on biodiversity

22

Stewardship Report 2022

Using this data, we believe that we can gaina general view of a company's performance,
impact, and dependency on biodiversity. With
the maturing of the methodology and thegradual implementation of regulations, we see
this list as being in constant evolution and strive
to integrate more data points over time.
Our ESG analysts also have access to informationfrom additional sources beyond these extra
financial data providers, including:– Dialogue with companies’ management andstakeholders,– Companies’ publicly disclosed documents,

October 2023

This creates a direct feedback loop fromengagement activity into the ESG ratings andanalysis – and subsequently into the investment
decisions of portfolio managers. These sourcesof information form an essential component in
the ESG analysis process as they allow analysts
to crosscheck information and data on specifictopics, as quality and reliability of information
is essential. All the information provided byexternal suppliers, once quality checked andfiltered through the professional assessment
by our analysts, feeds into our internal portfolio
management system (ALTO) which is available
to all portfolio managers.

– Equity and credit analysts of the AmundiGroup,– Sectoral experts,– NGOs, scientists, unions, media, brokers sellside reports, and– Bloomberg, Reuters.

➜ Our progress in 2022
Reinforcing a robust ESG data processing and rating process
In April 2022 we completed the transfer of responsibility for the integration of ESG data andthe monthly calculation of ESG scores from the Responsible Investment team to the Global
Data Management department.
This team now comprises of six ESG data specialists, who are responsible for ESG data
integration and quality for around 20 data providers.
This transfer allowed us to strengthen relationships with our data providers to improve quality
and service. It also allowed for better quality controls throughout the value chain: at the levelof sourcing of provider files, pre- and post-integration of data into the repository.
The Global Data Management team also support Amundi’s business lines on issuers relating to
raw data and ESG scores: ESG, Investment, Risk, etc.

23

Stewardship Report 2022

October 2023

B. The role of external providers to support our voting activity
Amundi’s Voting and Corporate Governanceteam (part of the ESG Research, Engagement
and Voting team) also relies on services fromexternal providers.
Analysis from ISS, Glass Lewis, and Proxinvest isavailable to more efficiently identify problematic
resolutions, while retaining complete autonomy
over their recommendations. ISS also provides
customised voting recommendations basedon Amundi’s voting policy. Using research andrecommendations from multiple proxy advisers
allows the Voting and Corporate Governanceteam to make informed voting decisions, taking

into account different viewpoints. The voting
decisions are also informed by the dialogue
the Voting and Corporate Governance teamundertakes with companies, as well as the viewsof internal experts, including the Responsible
Investment team.
Amundi uses the ProxyExchange platform,
provided by ISS, to monitor voting positions andsend instructions in accordance with Amundi's
voting policy. The only exceptions to adheringwith the voting policy are to align with specificclient mandate voting policies.

C. ESG analysis at the core of our investment platforms
Amundi’s ESG analysis is embedded into ourportfolio management systems. Portfolio
managers and investment analysts from all
investment teams have real time access tocorporate and sovereign issuers’ ESG ratings,
alongside financial ratings and related ESG
analytics and metrics. This enables fundmanagers to factor sustainability risks into
their investment decision process and apply

Amundi’s exclusion policy whenever applicable.
They are also able to design and manage theirportfolio(s) in accordance with any strategy/
product-specific ESG rules and objectives that
may apply.
More detail on Amundi’s exclusion policy and
ESG ratings methodology can be found in
Principle 7.

24 Stewardship Report 2022

October 2023

4. Integrating ESG considerations within remuneration
structures
ESG is integrated into remuneration structures
across the organisation, from the CEO
downwards in accordance with Article 4 of
the Internal Regulations of Amundi’s Board of
Directors, which specifies that the Compensation
Committee “analyses the remuneration policy
and its implementation with regard to social andenvironmental issues”.

Sales and portfolio managers remuneration
From 2022 onwards, Amundi will progressively
integrate ESG objectives into the performance
evaluation of sales representatives and portfolio
managers, directly influencing their variable
remuneration.
Responsible Investment team renumeration

ESG and climate issues are taken into accountin the Group's remuneration policies at several
levels and in multiple phases.
Executive renumeration
Reflecting the strategic importance of theseissues, a portion of the variable remuneration
attributed to Amundi's CEO is tied toenvironmental, social and governance indicators.
As of 2022, and subject to approval by theGeneral Meeting, 20% of the performance
evaluation and remuneration of the CEO willtake into account ESG and CSR objectives.

The variable remuneration of the Responsible
Investment team is based on both qualitativeand quantitative analysis of their effectivenessand delivery against expectations, alongsidebroader profit sharing based on Amundi’s overall
performance. All Responsible Investment 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.

Factors considered in this evaluation include
the implementation of the ESG Ambitions 2025
plan, the gender diversity of management
bodies and the achievement of the Human andSocietal project of Crédit Agricole SA.

➜ Our progress in 2022
– ESG objectives were incorporated in the annual objectives of 99% of portfolio managers
and sales representatives and were a determining factor in their variable compensation– ESG objectives under the “Ambition 2025” plan accounted for 20% of the criteria
supporting the performance share plan awarded to 200 Amundi senior executives– Assessment of the performance of the Chief Executive Officer and the Deputy Chief
Executive Officer was based on ESG and CSR objectives for a minimum of 20% (taking into
account the implementation of ESG projects accounting for 10% for the Chief Executive
Officer and 15% for the Deputy Chief Executive Officer and the Crédit Agricole S.A. Group’s
Customer, Human and Societal Project accounting for 10%)

25 Stewardship Report 2022

October 2023

Principle 3
Signatories manage conflicts of interest to put the bestinterests of clients and beneficiaries firstAmundi takes conflicts of interests very seriously and actively works to identify, prevent andmanage them. For this reason, the firm has put in place numerous measures to drive transparency
and ensure that potential and actual conflicts are monitored and dealt with.

Illustration 8: General measures to minimise and monitor conflicts of interest

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___Crédit Agricole Group is Amundi’s parent
company but we are an independent organisation
with an established board of directors andfive specialist committees: Strategic and CSR,
Audit, Risk Management, Compensation, andAppointments. Full details of all board member
commitments are published in our Governanceof Amundi Company document, which outlines
their existing and former positions in Crédit
Agricole Group companies, as well as otherlisted and unlisted companies.

Information barriers (physical, organisational,
procedural and IT barriers) are in place to avoid
the risk of conflicts of interest and the improper
circulation of confidential and inside information.
Amundi has defined a universal common basis
for its voting policy based on the fundamental
governance principles and shareholder rightsthat Amundi expects to be applied and respected
globally. Amundi exercises its stewardship
responsibility on behalf of its clients on all fivecontinents. That said, the implementation of

26 Stewardship Report 2022

this policy is adapted to each of these local
contexts. Our decisions are always made witha view to defending the interests of our clientsby supporting 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.

October 2023

We have a specific focus on Companies linked
to Amundi and specifically Issuers with acontrolling interest in Amundi as Crédit Agricole.
In addition, we do not vote on Crédit Agricole
resolutions as part of our relationship with thecompany.

The voting control system is based on the voting
policy, the existence of a voting committee todeal with delicate situations, and the posting ofall votes on the Internet.

Case study 1: Voting conflict of interest between Amundi and Crédit Agricole
Context: Amundi had to vote in April 2022 for an AGM of a French based company where
Crédit Agricole is controlling almost 20% of the capital.
Amundi Action: Amundi voted against the re-election of an independent board member given
the low attendance rate at Board and committee meetings during the previous year as wellas during the last three years. Amundi is vigilant about the necessary availability of Board
members, taking into account the number of mandates they hold and the attendance rate.
In case of a low attendance level, we expect companies to provide a cogent rationale. We
informed the company of our voting intentions.
Engagement Outcome & Issuer Momentum: The level of dissent was 22% on this resolution.

A. Policies and procedures
We recognise that Amundi Group entities may
be exposed to potential conflicts of interest
when carrying out transactions or entering into
service contracts with entities within our Group,
entities of our parent Group, as well as with third
parties.
In order to manage this, we have put in placeinternal rules and procedures to ensure andrespect each client’s interests – including, but
not limited to, our Conflicts of Interest Policy
and Code of Conduct.
Our specific rules of conduct, vis-à-vis clients,
mean all employees must:– Ensure and respect the primacy of eachclient’s interest, particularly in relation to theirpersonal interests and/or the Amundi Group’s
interests,– Avoid situations where they may need tochoose between their personal interests,
whether financial or otherwise, and theAmundi Group’s interests or those of its
clients,– Respect the principle of equal treatment
among clients,– Not disclose to a client confidential
information about a client that has cometo their attention in the course of theirprofessional activities. This does not apply to
information that is or has become public.
The Amundi Code of Conduct is the fruit of acollaborative approach between our different
business lines; Retail and Institutional Marketing,Purchasing, Compliance, Legal, HR, Corporate
Social Responsibility and Communications,among others.

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Stewardship Report 2022

Beyond compliance with legislative, regulatory
and professional rules, the Code of Conduct,
which applies to all of our operations,reflects our commitment to carrying out ouractivities with the highest ethical standards
and professionalism and to acting in the bestinterests of our customers.
Other examples of the robust policies andprocedures we have in place to safeguard clientinterests include:

October 2023

Gifts and benefits
Employees must not accept a gift or any otherbenefit from a third party that could put themin conflict with their responsibilities. All gifts
and benefits received must be disclosed at least
once per year and may not exceed the maximum
amount set per business relationship per year. If
this cap is exceeded, the employee must justify
it and request the authorisation of their manager
and the compliance officer before accepting.

Employee remuneration
Each Amundi Group entity is tasked with ensuringthat remuneration structures do no lead, directly
or indirectly, to potential conflicts of interest.
This could include ensuring remuneration basedon sales targets does not incentivise employees
to recommend one product over another thatmight better fit the client’s needs. All entities
have policies and practices in place that take
into account the interests of all clients in orderthat these interests are not negatively affectedin the short, medium or long term.

Employee training and awarenessIn addition to written policies and procedures,
we include conflict of interest training in the
training plan for our employees. Amundi maps
the various conflicts of interest that may ariseand damage the interests of clients. These
scenarios are regularly updated and inform ouremployee training and policy development.

B. When conflicts of interest arise
While Amundi employees strive to avoid
conflicts of interest, there are clear policies
and procedures in place outlining the action totake should one arise. In the first instance, theemployee involved must immediately alert theirdirect line manager as well as their complianceofficer.
Potential conflict of interest cases are jointly
analysed by the Compliance Department
and relevant business line, with two possible
outcomes:– Where a conflict has previously arisen andis included in the scenario mapping, theexisting control process must be applied.
– Where the conflict presents a new scenario,
the Compliance Department and businessline must carry out an analysis of the conflictand define its framework. The mapping willthen be updated to inform future action.

All Amundi Group entities maintain andregularly update a conflict of interest register,
outlining the times a conflict has arisen and theaction taken. This register is maintained by therelevant compliance officer for each entity and isavailable to the Group Compliance Department.
Where a conflict has been identified, every effort
is made to find an appropriate solution and avoid
any client harm. Where we are not reasonably
certain that damage to the client’s interests
can/has been avoided, the client is informed.
The information shared with them is sufficiently
clear and detailed – and officially recorded - toenable the client to make an informed decision
about what action they wish to take.
Mapping was updated in 2022 with 64 conflictof interest scenarios. More details are available
in section 2.B of this principle.

28 Stewardship Report 2022

October 2023

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 tobroad measures taken at group level, specificcriteria apply when it comes to our stewardship
responsibilities.

A. A global setup intended to prevent conflicts of interests
The company maintains a strict segregation ofits voting and stewardship function away fromour client relationship divisions, this is done
to minimise any potential conflicts and ensure
effective stewardship.
In addition to our Conflicts of Interest policy and
Code of Conduct, our stewardship activities areunderpinned by strict procedures asserting the
primacy of clients’ bests interests and our ability
to form an ad-hoc committee to address arisingand potential conflicts.

For example, any voting decision in relation to
Amundi’s partner and joint venture companies is
automatically escalated to the Voting Committee
and the decision-making on all votes is fully
documented – with particular attention to any
situation where the vote is not in accordancewith the usual Amundi voting policy.
Our Remuneration Policy also ensures thatthe interests of our senior management andinvestment staff align with those of our clients.

B. Voting on companies that have links with Amundi
When exercising the voting rights of our openended funds, Amundi may face potential
conflicts of interest. Measures to prevent andmanage such risks have therefore been put inplace.

In addition to these previously identified issuers,
the Voting and Corporate Governance team also
submits to the voting committee any potential
conflicts of interest that may result from theanalysis of resolutions from general meetings.

The first preventive measure is the definitionand publication of the voting policy validated
by the management bodies of the group’s
management companies.

Using our voting power with our clients

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 whicha potential conflict of interest has beenpreidentified, 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.

During the 2022 voting season, Amundi had
to vote on behalf of its clients at the General
Meeting of one of its biggest clients. We
recommended the voting committee voteagainst the remuneration report for the chief
executive officer due to multiple concerns
regarding the structure and level of his
remuneration. In particular, we were concernedthat the total compensation was far above
other local competitors, which means the CEO
pay could be considered ‘unacceptable’ froma societal perspective and give rise to some
controversy. Moreover, part of the CEO’s variable
remuneration did not include any performance
criteria or included performance metrics thatwere insufficiently challenging.

29 Stewardship Report 2022

October 2023

While Amundi expressed these concerns to the company through our various engagements, thecompany’s response did not alleviate our concerns, as the rationales provided were not consideredsatisfactory. The voting committee supported the decision to vote against, notwithstanding theexistence of the conflict of interest.

➜ Our progress in 2022
– Examples of specific measures implemented or enhanced in 2022 are described below. Ourpolicy on managing and preventing conflicts of interest was updated in September 2022.
It now incorporates vigilance and supervision measures in respect of conflicts of interest
implemented within the Group and relating to socially responsible investment to stick to
Amundi’s ESG strategy.
– The internal framework was also reinforced with updates on all our conflict of Interest
pillars, which includes prevention measures and covers the management of conflicts of
all Amundi employees. It incorporates a risk mapping with 64 updated conflict of interest
scenarios with details on the prevention and controls measures as well as applicable
procedures. It also includes a description of the control framework. All employees are
required to complete a conflict of interest declaration and attestation on an annual basis.
– A new training programme on conflicts of interest will be rolled out in Q2 2023 for all theentities of Amundi Group, developed in collaboration with Crédit Agricole– We will continue to enhance our approach with regards to conflicts in the area of ESG andstewardship specifically, to ensure that clients have full confidence that we continue tooperate solely in their best interests.
– In 2022, Amundi voted on all holdings for which it was economically viable to do so. Thisequated to 99% of the total votable assets, which saw us vote at 10,208 shareholder
meetings.

Shareholder meetings participation
12000
10208

10000
7309

8000
6000
4241
4000
2000
0
2020

2021

2022

Shareholder meetings participation

30 Stewardship Report 2022

October 2023

Principle 4
Signatories identify and respond to market-wide andsystemic risks to promote a well-functioning financial
system.
Amundi has a culture of prudence and has developed a comprehensive framework to identify,
manage and mitigate the risks associated with its activities. We believe that a well-functioning
financial system can only be achieved by the combination of rigorous risk management atentity level, with a commitment to promoting best practice through risk-management related
innovations and partnerships.
Our internal control and risk management system is written in accordance with the guidelines
laid out by our parent company Crédit Agricole, which are designed to ensure a consolidated
approach to risk. These external guidelines are supplemented by Amundi’s own charters,
standards and internal procedures in the areas of risk monitoring, including IT and accounting;compliance checks and internal audit.
The internal control system applies equally to all Amundi Group entities and covers the
management and control of activities, as well as the measurement and monitoring of risk.
Amundi understands that risk is multi-facetedand operates over different timeframes.
This requires us to look beyond market risk
and take into account credit, liquidity, andreputational risks, as well as ESG risk generated
by a company’s activities. Our investment

professionals are supported by an independentrisk department with a broad scope, and an ESG
team that has access to specialist research andcan provide its own in-depth analysis of ESG
risks likely to impact portfolios.

1. Rigorous risk management to frame our activities
a. A group-wide approach to risk management
Amundi’s approach to managing risk is basedon a high level of integration of the Risk
Management business unit across the whole of
the Amundi Group. This ensures a uniformityof process, the pooling of resources and a highlevel of team expertise, by way of dedicatedcentres of competence.
The Risk Management business unit is organised
as a matrix, consisting of:– Cross-business Risk Management
Departments, which determine the broad
methods for controlling and monitoring risk
related to the way funds are managed andprovide supervision of this risk. The goal ofthese departments is to integrate all risk andperformance factors and indicators for eachfund analysed, and to ensure the internalconsistency of these indicators and theirsuitability to a fund’s objectives.

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Stewardship Report 2022

– Risk teams in each subsidiary that manages
assets, which oversee the risks andfunctionally report to a department head.
– Teams specialised by field of expertise
which are brought together in a dedicateddepartment whose mission is to ensure
consistency across business lines of theapproach taken for each type of risk. The
main missions of these departments are
to define the standards and methods formeasuring risk, produce the risk indicatorsand provide expertise in applying thesemeasures to the portfolios.
A dedicated team is in charge of steering theoperational risk monitoring system. Its main role
is to:– Map operational risk at the Amundi level,– Collect information about operational
incidents,– Monitor all action plans designed to mitigate
this risk,– Contribute to calculating the capitalrequirement, and– Contribute to the Permanent Control system.
Amundi takes a comprehensive approachto managing operational risk, with all teams
and managers involved. Periodic reports aresent to Senior Management and the Board of
Directors on the controls carried out by the
Risk Management function. In 2022, Senior
Management was regularly updated about:

October 2023

– The Risk Management function’s monthly
scorecard, which provides a detailed reviewof the Group’s exposure to various risks andsensitive matters,– The updates provided by the Head of Risk
Management to the Executive Committee,– The Risk Management business unit’s
various governance committees which
Senior Management takes part in; including
Amundi’s Group Risk Management
Committee, which the head committee of the
Risk Management system.
The Board of Directors also receives regularpresentations from the Risk Management
Committee, which cover the risk management
system, its current state and any changes to it;
along with a summary of risks, changes in risk,
the level of the main risk limits and usage of
those limits.
The main changes to the risk monitoring system
in 2022 related to the continuation of work
started in previous years around liquidity risk,
particularly in relation to European Securities
and Markets Authority (ESMA) regulations, andthe implementation of an ESG risk framework.
In addition, Amundi’s acquisition of Lyxor, which
was announced in April 2021 and completed in
January 2022, saw risk frameworks deployed
for ex-Lyxor funds during the incorporation of
the company’s business activities into Amundi
entities.

b. Identification of market-wide risks
Asset management is first and foremost a risk
management activity, which is why Amundi
constantly ensures that our organisation andprocesses enable us to identify and contain risks.
2022 was a year marked by several significant
market-wide risks: among them the ongoing
war in Ukraine, high inflation, high interest rates,
the re-opening of China and the end of the
global pandemic.
Our approach is characterised by the sharingof expertise and best practice so that we canbest understand and manage these risks. This isfacilitated by:– Operating across business lines,– Ensuring the systematic representation of
the Risk, Compliance and Security functions
on the various committees involved (such as
products, investments and ESG),– Combining our applications and risk
measurements methods onto a single
IT platform, creating a common set of
guidelines for all teams,– Establishing initiatives to discuss and provide
information on the various risks associatedwith the company’s activities, and– Educating employees about new risks thatappear, and changes in the regulations
governing them, through e-learning sessions.

32

Stewardship Report 2022

October 2023

Maintaining a risk culture also involves making
clients aware of the risks to which their assets
are exposed. Amundi publishes studies for its
clients which describe these risks and how they
are affected by economic conditions, as well as
the solutions put in place by the management
team to capitalise on them.

Amundi also shares with its clients a monthly
outlook produced by the Amundi Investment
Institute of market-wide risks and potential
evolution scenarios across 4 pillars: geopolitics,
inflation, growth and climate change. This isintegrated within the monthly Cross Asset
Investment Strategy publication on Amundi
Research Center

Illustration 9: The invasion of Ukraine
On February 24 2022, the Russian Federation launched a large-scale armed attack on Ukraine.
The continuing invasion has not only led to the fastest-growing refugee crisis in the world, but
has also triggered a massive shock to the global economy, squeezing supply and pushing up
prices to record levels.
In response, Amundi prioritized timely and accurate dissemination of information to all our
stakeholders. This was achieved by continuously sharing updates on the market and impact on
portfolios as the crisis evolved. Our investment teams, along with risk specialists and in-houseeconomists (Amundi Investment Institute), proactively monitored developments across theregion and the impact on our client portfolios. Timely information and investment view werealso made available through numerous channels of communications: 12 articles on Amundi
Research Center, 11 dedicated client calls, 2 podcasts, specific client Q&As, etc.

Amundi directors are asked to take part in two
training sessions per year to enhance theirknowledge and skills and give them a morethorough understanding of the company’sbusiness lines and strategic challenges. In
2022, one of the sessions included an overview
of European regulatory news, as well as apresentation of the Financial Security systemand how it adapts to the needs arising from theRussia-Ukraine conflict.

In the course of its business activities, Amundi
is primarily exposed to risks related to thirdparty asset management activities and financial
risks, mainly arising from the management of
its investment portfolio and the guarantees
granted to certain products. The table below
provides a summary:Investment risks

Other risks– Credit risks– Operational risks– Market risks– Liquidity risks– ESG risks- Mandate objectives- Process malfunction, human error;- Non-compliance, tax and legal;- Business discontinuity (including cybersecurity);- Human Resources.
– Business risks– CSR risks (including duty of care, corruption)

33 Stewardship Report 2022

October 2023

c. A dedicated internal control system supported by adequate
resources
The internal control system referenced at thestart of this principle covers the entire Group in
France and internationally, and is based on thefollowing fundamental principles:– Systematic reporting to the Board of
Directors in relation to the risk management
framework, the monitoring of set limits, theactivities and results of audits carried out
by the various parts of the internal control
system, as well as significant incidents,– Direct involvement of Senior Managementin the organisation and functioning of theinternal control system,– Comprehensive coverage of activities andrisks,– A clear definition of responsibilities, througha system of formal, up-to-date delegations,– Effective segregation of commitment andcontrol functions.

Internal resources dedicated to risk and control management

262
Risk
Department

150

ComplianceDepartment

The
Risk
Management
Departmentis
responsible for monitoring the risk to which
Amundi is exposed on its own account and as
manager on behalf of third parties, with the
exception of non-compliance risk and security
risk. In this regard it:– Continuously checks that the company andits clients are not exposed to financial risk
beyond their tolerance levels,– Ensures that investment constraints arecomplied with, and– Checks that operational risk is controlled.
The Compliance Department is responsible
for monitoring non-compliance risk andcontinuously ensures compliance with legislativeor regulatory provisions, and professional andethical standards, particularly in terms of:– Market integrity,– Financial security,– Protection for clients and unitholders,– Professional ethics, and– Prevention of fraud and corruption.

29

Security
Department

49
Internalaudit

In addition, it is responsible for checking
employees have a minimum level of knowledge
regarding the regulatory and ethical environment
and financial techniques.
The Security Department is responsible
for monitoring the risk associated with theinformation system; namely IT infrastructure,applications and data, as well as the risk relating
to personal data protection, business continuity
and the protection of persons and property.

34 Stewardship Report 2022

October 2023

Illustration 10: Market integrity and transparency
Investment service providers such as Amundi are required to act in an honest, fair andprofessional manner that promotes market integrity. Plans to strengthen controls in this area
were finalised in 2022 at the portfolio management and trading in financial instruments level.
This involved significant IT developments in our market abuse monitoring system, which saw a
new tool implemented to detect suspicious transactions.

2. Identifying and addressing systemic risks _____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. We have the ability and the

responsibility to channel capital to the leading
actors addressing key ESG and sustainability
challenges, or on the contrary to put pressure
on laggards, as part 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, the integration of ESG factors in ourinvestment process makes it possible to capture
the most important and relevant information
over the long term.
As far as sustainability risk is concerned,
Amundi’s contribution to the collective effort isthrough:– 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), and– The promotion of good practices in risks
areas by contributing to collective initiatives(see Principle 10 for more details on theseactions).

a. Taking a collaborative approach
Amundi works with all stakeholders to anticipate
and respond to a wide range of economic,
technological and environmental challenges.
Maintaining constant dialogue with our clients,
peers, Amundi employees, NGOs and public
and regulatory authorities, among others, helps
us to understand their expectations and fosters
trust.

The Group also adheres to various international
charters, including the United Nations Global
Compact, the Principles for Responsible
Investment, the Net Zero Asset Managers
Initiative, as well as the Diversity Charter. We also
participate in more than 25 collective initiatives
aimed at working with public authorities toencourage more sustainable practices.

35 Stewardship Report 2022

October 2023

➜ Progress in 2022
In 2022, Amundi’s Chief Responsible Investment Officer, Elodie Laugel, was one of 20 highly
qualified individuals chosen to join the European Commission’s High-Level Expert Group (HLEG).
The first meeting was held in September 2022 and the group was tasked with identifying,over the following nine months, how the Commission could take a ‘Team Europe’ approach
to bringing about the needed financing from the private sector for the massive investments
required to tackle the most pressing global challenges and ensure sustainable development.
The recommendations will inform a comprehensive strategy to scale up sustainable finance inlow- and middle-income countries.
We also joined the Global Investors for Sustainable Development Alliance (GISD) in 2022, andthe Council of Institutional Investors (CII).

b. Integrating ESG risks into risk management processes
The year 2022 once again demonstrated whytackling climate change and biodiversity loss
- while limiting its social impact - are key forour economy. A major transformation can
only occur if it is done in an organised manner
between governments, customers, companies
and financial markets. This will limit the negative
impacts on employees, end savers, pensioners
and territories across the global.
ESG criteria are integrated into our control
framework, and responsibilities are divided
between the Investment teams, our first level ofcontrol; and the Risk teams, our second level ofcontrols.
The Risk teams may at any time assess thecompliance of a fund with its ESG objectives
and constraints.

The Risk Department is part of a governanceframework
designedaroundresponsible
investment. It monitors compliance withregulatory requirements, as well as the
management of risks related to these issues.
Responsible investment rules are monitored by
the Risk teams in the same way as any otherrule under their purview, using the same tools
and procedures. These rules include exclusion
policies, eligibility criteria and fund-specificrules.
Compliance checks for these rules are automatedin the form of an internal compliance tool withpre-transactional 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.

c. Physical and transition risk identification and assessment
Amundi’s decision to focus on physical andtransition risk stems from our conviction thattackling climate change while managing thesocial impact of the energy transition is an
integral part of sound risk management. It isalso important for creating long-term value forour clients.
Since 2020, Amundi has strengthened andexpanded our approach to include identifying
and assessing sustainability risks, including
physical climate and transition risks, andincorporating them into the key indicators thatare considered in the investment process.
Our indicators and targets help us to identify,
qualify and effectively manage climate-relatedrisks and opportunities. Using a wide range ofindicators, Amundi is able to set short-, mediumand long-term targets. For this purpose, we rely
on a broad set of data providers to guarantee
our measurements and assessments are as
accurate as possible.

36 Stewardship Report 2022

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, our 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 each company’s sector andgeography, and increased climate risk can have asignificant impact on the financial performanceof sectors with high climate risk.
Amundi's approach to physical climate risk
assessment is based on data and methodology
developed by Trucost. Trucost maps thelocation data for a company's physical assets
against seven climate hazards (fire, cold wave,
heatwave, sea level rise, flood, tornado anddrought) to analyse issuers’ sensitivity to thesedifferent risks.
Process for identifying and managing climate,market and transition risks

October 2023

Amundi takes a three stage 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
the performance of a portfolio of securities.
Several tools are available to our investment
professionals to apply this approach inpractice.
Commitment to the Net Zero Asset Manager
initiative
In 2021, Amundi joined the Net Zero AssetManagers initiative and announced its intention
to gradually align its portfolios and operations
with a net zero emissions target to limit global
warming to 1.5°C by 2050. The Net Zero AssetManagers initiative is a group of 315 global
asset managers with $59 trillion in assets undermanagement who have pledged to support thegoal of zero net greenhouse gas emissions by
2050 or sooner, consistent with global efforts
to limit warming to 1.5°C, and to support
investment aligned with this goal.

➜ Our progress in 2022
One year after joining, Amundi restated our commitment to the initiative and outlined our“Ambition 2025” plan in accordance with these goals. We launched the first products in our
Net Zero Ambition fund range, in line with the commitment to offer such products across all
asset classes and investment styles.
This approach required immediate transformation efforts on three fronts:– Products - by increasing the number of investment solutions aligned with a Net Zero
trajectory for all types of investors;– Clients - by advising them on how to align with the Net Zero objective; and– The companies in which Amundi invests - by encouraging them, through constant dialogue,
to adopt and implement credible transition plans towards the global Net Zero objective
Members of the board also received training on the various ESG regulations relevant to asset
management in 2022.
More information on the scope and progress of the “Ambition 2025” plan can be found in
Principle 1.

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Stewardship Report 2022

Integration of sustainability risks
Amundi has been working on improving theassessment and incorporation of sustainability
risks, including climate and environmental risks,
in their management.
We aim to move from a qualitative to a morequantitative approach. The objective is to
identify key indicators that represent the most
relevant impacts on portfolios, considering
climate, environment, social, and governancefactors.
The project is structured in three steps:– Defining a list of proposed sustainability risk
indicators, focusing on material risks andtheir financial impacts on issuers,– Implementing the monitoring of these
indicators progressively, assessing their
outputs and potentially setting limits basedon them.
– Upgrading the ESG Risk Management
framework, including the incorporation ofindicators into risk strategies and investment
limits.
The current ongoing step involves identifying
key sustainability risk factors and mapping themto financial variables of issuers. It is expected

October 2023

to be completed by the end of the second halfof 2023, with the validation and approval ofindicators by Amundi's governance bodies.
Preliminary indicators under consideration
include measures that quantify the potential
impacts of sustainability risks in terms offinancial materiality and proxies for reputationalrisk.
The second step,
involves monitoring thedefined sustainability risk indicators andassessing their impact on managed portfolios.
This monitoring will inform discussions withportfolio management teams and be included
in various risk management reports.
The third step focuses on upgrading the ESG
Risk Management framework and potentiallydefining internal risk alerts or limits based on
the indicators. The estimated completion forthis step is the first half of 2025.
It should be noted that the deadlines, indicators,
and target implementation may be subject tochanges during the project's implementation
phase.

3. Commitment on three specific frontiers to promotea well-functioning financial sector
Mobilising the private financial sector at scaleremains one of the most significant challenges
when it comes to financing climate policy
and sustainable development, particularly in
Emerging Markets and Developing Economies.
Blended finance can be a solution, where public
capital is leveraged to de-risk private investments
and channel massive private investments acrossa multitude of works. This works to develop
key financial system infrastructures, support
undeveloped segments of a market, while
offering international investors investment
opportunities with the right risk/return via
mechanisms that include, but are not limited to,guarantees or credit enhancements.

38 Stewardship Report 2022

October 2023

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 2022, the partnership continued to play its role by:– Financing sustainable development in emerging countries. Despite challenging market
conditions, AP EGO maintained its “greening” path, with an allocation of more than 80%
in emerging market (EM) green bonds at the end of 2022 (well above the targeted 50%)
notably by participating in new issuances from first-time issuers of EM green bonds
highlighting AP EGO’s commitment to expanding financing for climate investments.
– Conducting training for EM financial institutions on green bond issuance to further
stimulate growth of EM green bond issuance: In 2022, the GB-TAP had its most active year
to date with 12 Green, Social and Sustainability (GSS) Bonds Executive trainings programs.
Since the inception of the funds, a total of 895 participants (42% women) from 323 financial
institutions located in 65 different countries have been attending trainings.
– Disseminating knowledge and best practices in issuing green finance through two
dedicated webinars and the publication of three market guides to enhance issuer reporting(the Green Bond Handbook in April 2022, the Green Finance Reference Guide in August
2022, the Biodiversity Finance Reference Guide in November 2022)– Fostering dialogue with companies in emerging countries to strengthen their commitments
towards environmental, social, and governance and reporting practices.

EM green bond ramp-up progress
%
100

100%
54%

80

70%
60

54%
46%
50%

40

20

32%
17%

40%
25%
Current

15%

Guideline

0
End Y1End Y2End Y3

End Y4

End Y5

Source: Amundi, fund data as of 31/12/22 on a mark-to-market basis.

Number of green bonds in portfolio:

39

Weight of green bonds in the portfolio: 80.9%

End Y6

End Y7

39 Stewardship Report 2022

October 2023

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 $300 million fixed income portfolio, actively managed by Amundi teams, which seeks
outperformance by identifying, analysing and selecting tomorrow’s Climate Champions.
As of 2022, the portfolio key allocation (36.5%) was comprised of bonds issued with the aimof financing infrastructure programs across a well-diversified number of sectors such as power
and renewable electricity production, telecommunication services, transportation and utilities.
Almost a third of our allocation was dedicated to financing projects from other productive
sectors, such as automobiles, chemicals, paper & forest products, semiconductor and electronicequipment, totalling an exposure of 30.5%.

AIIB Sector allocation
PrivateEquity1 000
Private debt
8 500

Social Impact
investing440
Green Infrastrusture
427

Multimanagement
10 400Real Estate
41 900Source: Amundi. Data as of 31 December 2022

40 Stewardship Report 2022

October 2023

Case study 4: Issuer frontier - Private debt markets
Launched in 2019 by Amundi with the support of the European Investment Bank, the Green Credit
Continuum (GRECO) programme aims to support the most impactful, yet underdeveloped,
segments of green debt markets in Europe: high yield issuances, securitisations and private
debt.
The Fixed Income space experienced its worst year in terms of performance in 2022 by historicalstandards. In particular, the Green labelled bond segment had a quite challenging primarymarket amid the significant meltdown mainly driven by the energy crisis and the substantial
rise in interest rates leading to a tough macroeconomic environment exacerbated by the war
in Ukraine.
During 2022 the fund managed to complete 6 new transactions across 5 European countries
and over different sectors, mainly in the High Yield space and across several sector contributing
to the portfolio diversification. Overall, the fund has completed 22 transactions, where 18 of
those were first green bond issuances and 15 target operations were in the High Yield segment.
Europe, and particularly France, remains the domicile of most of the deals.
Active participation in Green Bond Principles Executive Committee
The Green Bond Principles (“GBP”), the Social Bond Principles (“SBP”) and the Sustainabilitylinked Bond Principles (“SLBP”) are voluntary guidelines that recommend transparency andpromote integrity in the development of the Sustainable Bond markets by clarifying theapproach for issuances.
Through global guidelines and recommendations that promote transparency and disclosure,the Principles outline best practices that ensure integrity when issuing bonds serving social orenvironmental purposes. In 2022, 98% of sustainable bonds globally (excluding supranational
issuers) were aligned with GBP, SBP and SLBP highlighting the recognition of these international
standards by the market.
The Principles are promoted by the International Capital Market Association (ICMA), a not-forprofit membership association headquartered in Zurich, and offices in London, Paris, Brussels
and Hong Kong, with c. 600 members active in debt capital markets in over 60 countries, suchas private and public sector issuers, banks and securities dealers, asset and fund managers andother investors, insurance companies, capital market infrastructure providers, central banks,
law firms and others.
Since 2017 and after the renewal of its 2-year mandate, Amundi is a member of the Executive
Committee of the ICMA’s Principles and as an investor (option 1) plays an active role addressing
matters relating to the Principles (or option 2) representing the interest of investors e.g., thedevelopment of Sustainable Bonds market, the standardization and impact reporting practices.
Active participation in High-Level Expert GroupThe High-Level Expert Group (HLEG) on scaling up sustainable finance in low and middleincome countries started in 2022 their reflection on the challenges and opportunities ofsustainable finance in partner countries with a view to providing recommendations to theCommission on how to scale up funding from the private sector.
At a time when the multiple global crises are taking a heavy toll on the global economy,
overturning years of progress towards the Sustainable Development Goals (SDGs), helping
partner countries in accessing finance for their sustainable infrastructure projects is critical toa global recovery, in line with the Global Gateway strategy.

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Amundi Chief Responsible Investment Officer & Executive Committee member Elodie Laugel
belongs to the group of 20 highly qualified members selected based on their expertise, froma company or institution they represent, while considering geographic and gender balance.
Engaging on climate under “Ambition 2025”
After joining the Net Zero Asset Managers initiative in July 2021, Amundi launched a plan in
2022 to achieve decarbonisation more quickly. ESG “Ambition 2025” is a social and climate
action plan that seeks to deepen ESG integration into our investment solutions, strengthening
our savings offering for sustainable development and setting internal objectives that align with
Amundi’s ESG commitments.
As we believe engagement with issuers is key to fostering concrete changes and to contributing
effective to the transition towards a low carbon economy, Amundi will extend the scope of our
dialogue to larger groups of companies to support them in making progress towards reducing
emissions and becoming aligned with the Paris Agreement.
In 2022, as part of our Ambition 2025 plan, we launched a cycle of engagement on climate
issues that will see an additional 1,000 companies engaged by 2025. Amundi specificallyrequests that businesses publish a detailed climate strategy based on specific indicators andset out objectives for each carbon emission scope and their corresponding capital expenditure.
In 2022, Amundi engaged an additional 418 companies on climate issues.
This engagement covers all ESG issues. Beyond the specific topics for climate change, in
2022, specific thematic commitments included the circular economy, biodiversity, for which a
specific report was published on our website, deforestation, ocean protections, strategy forealignment with the Paris Agreement, the just transition, human rights, living wage, as well as
fair distribution of added value within companies.
More detail on the “Ambition 2025” plans objectives and progress to date can be found in
Principle 1.
Biodiversity loss related risks
Amundi believes biodiversity loss is one of the most significant systemic risks facing the world.
For this reason, we continued to sound the alarm in 2022 to highlight the very real risks thefurther loss of biodiversity pose to a well-functioning society.
Through a series of two in-depth papers3 and a thematic series covering 8 sectors exposed
to biodiversity, we shone a spotlight on the risks posed by biodiversity loss, the actions that
sectors and industries, such as mining and forestry, need to take to halt further erosion, andoutlined how Amundi holds our investee companies to account.
Biodiversity underpins not only our economy but also our very existence. Yet we – individuals
governments and the private sector – are only in the early stages of understanding how
essential it is. Food insecurity, human health and the increased severity of climate events all
have consequences for society and the global economy.

3 https://research-center.amundi.com/article/biodiversity-it-s-time-protect-our-only-home

42 Stewardship Report 2022

October 2023

Amundi is an active member of the Finance for Biodiversity Pledge. This initiative brings
together 103 financial institutions representing over €14.7 trillion in AUM across 19 countries
from around the globe, committing to protect and restore biodiversity through their financeactivities and investments.
We 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.
The World Economic Forum’s Global Risks Report4 has for the past six years identified
biodiversity loss and ecosystem collapse as a high level of global risk in terms of impact andlikelihood. The WEF also found in 20205 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.
More details of engagement on biodiversity can be found in Principle 9.

4. https://www3.weforum.org/docs/WEF_Global_Risks_Report_2023.pdf
5. http://www3.weforum.org/docs/WEF_New_Nature_Economy_Report_2020.pdf

43 Stewardship Report 2022

October 2023

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.

They also oversee our progress towards
delivering the changes necessary to fulfil
our “Ambition 2025” plan’s objectives (seePrinciple 1), having successfully achieved thosefor the 2018-2021 ESG plan.

– ESG Strategic Committee– ESG Rating Committee– Voting Committee– ESG Management Committee
More details on the four ESG committees in
Principle 2.

On specific funds, we have French Socially
Responsible Investment (SRI) labels in place andapply the International Financial Corporation’s(IFC) Performance Standards. A significant partof Amundi’s funds are certified by other Frenchor international labels, and are therefore audited
to ensure that the associated requirements
are verified. We reinforce these external
certifications through our internal assurance
and oversight processes.

44 Stewardship Report 2022

October 2023

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:

BoD Risk Management Committee and Audit Committee
Internal Control Committee

Permanent control
Level 3

Internal audit
Group Risk Management Commitee, Compliance Committee,
Security Committee
Position Risk

Permanent control
Level 2

Position ComplianceControls:

Controls:

Controls:– Investment– Operational– Own account

–
–
–
–

–
–
–
–

Financial security
Market Integrity
EthicsClient protection and
ESG– Fraud and corruption

Permanent control
Level 1

Position Security

IT security
Data protection
Business continuity
Safety and securityof people andproperty

Policies & procedures

Committees of Amundi's
BoD

Controls performed by operational entities using the principleof separation of functions and hierarchical controlsa. Level 1 Permanent Control
Level 1 Permanent Control provides thefoundation for the Internal Control system. It is
implemented by all operational units under theirhierarchy. Level 1 Permanent Control is designed
to ensure compliance with internal procedures
relating to the operational processes, and theircompliance with current laws and regulations,professional standards and codes of conduct. It
makes it possible to prevent or detect any risk
arising as a result of Amundi’s activities.
The executives of the operational units areindividually responsible for managing therisk associated with their activities. They
are responsible for the definition, efficient
deployment and regular updating of thePermanent Control system within their units.
The control system takes into account theregulatory framework and internal procedures. It
is understood that these procedures must evolveand be adapted to our clients’ expectations.
They must take into account improvements thatare expected in relation to any actual or potential
incidents, as well as the recommendations madeby Internal Audit.
The operational units obtain the resources
necessary to perform these controls andregularly communicate the results to the
Department to which they report, the Risk
Management Department, the ComplianceDepartment, and the Security Department.
The quality and relevance of the Level 1 controls
and the effective relaying of their results forLevel 2 control functions is an essential factor in
the efficiency of Level 2 controls.

45 Stewardship Report 2022

October 2023

b. Level 2 Permanent Control
Level 2 Permanent Control is performed
jointly by three control functions, which are
independent from the operational units:– the Risk Management function;– the Compliance function;– the Security function.
Collectively,
these
three
functionsareresponsible for the cooperative and coordinatedmanagement of the entire Permanent Control
system to verify that it provides comprehensive
cover of the risks Amundi is exposed to. The Risk
and Compliance functions report to the Head of
the Strategy, Finance and Control Division, andthe Security function reports to Amundi’s Headof Governance and General Secretary.
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.
The Compliance function is responsible
for monitoring noncompliance risk andcontinuously ensures compliance with legislativeor regulatory provisions and professional andethical standards.
The Security function is responsible formonitoring the risk associated with theinformation
system(IT
infrastructure,applications and data) as well as the risk relating
to personal data protection (under the European
regulations on the handling of personal data
and the free circulation of these data), business
continuity, and the protection of persons andproperty.

c. Level 3 Permanent Control
Amundi’s Internal Audit is in charge of the Group’s
periodic control; it ensures the lawfulness,security and effectiveness of all operations
and risk control activities across all Amundi
entities. It intervenes via audit plans approvedby the Board of Directors’ Risk Management
Committee to cover the activities at frequencies
appropriate to the risks of each activity. Each
audit results in a report and recommendations,to which the audited entities respond. The
effective implementation of recommendations
is monitored twice yearly by Amundi’s Internal
Audit. The General Internal Audit Department of
Crédit Agricole S.A. also conducts audits of theAmundi Group.
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 thanks to its audit recommendations.
Given the sensitivity on ESG topics and thematerial importance for Amundi to protect
its clients trust, Amundi may seek external
assurance, over and above these three levelsof control.

46 Stewardship Report 2022

October 2023

3. Dedicated control of data_________________
Amundi data Management team of experts runs
quality controls on the ESG data inputted into
our systems at different stages of the value
chain– The first, data-related quality control, is
performed on the files provided by suppliers.
– It covers, in particular: ➊ checking the files’
are delivered on time, ➋ their contents,
not least to ensure scores are up- to-date;and ➋ checking the format quality of thefiles provided by suppliers. The secondlevel controls ensure the integration quality
and scoring of the criteria. It is particularly
used to detect missing criteria, as well as
insignificant or anomalous values, missing
ISIN, duplicates… A third batch of controls
are applied post-integration to control
completeness and consistency at issuers
level.
Relevant alerts require members of the analyst
and quant team to review data at a level 2 side.

Every month, in order to update ratings, a ratings
simulation is computed by Data Management
team, controlled for consistency, completeness,
new and old exclusion, and is sent to the ESG
analysts and Quant team. Each analyst thenvalidates the ratings of the companies that they
he oversees
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– controls analyzing 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).
– exclusions are particularly looked after, withmultiple controls from the 3 teams.

Illustration 11: External assurance in the context of the Amundi responsible
Investment AUM publication
Amundi's statutory auditors have carried out procedures on the amount of assets undermanagement classified as Responsible Investments by Amundi of €847 billion as at 31 December
2021. Their report6 indicates that based on the work they have performed and the evidence
they have obtained, nothing has come to their attention that causes them to believe that the
information, is not prepared, in all material respects, in accordance with the Amundi reference
framework.

6. Available on Amundi website.

47 Stewardship Report 2022

October 2023

Principle 6
Signatories take account of client and beneficiary needs
and communicate the activities and outcomes of theirstewardship and investment to them.
Amundi acknowledges the fiduciary duty given to us by clients, who have entrusted their capitalto our care. We are dedicated to upholding that responsibility by prioritising their long-term
interests in our investment decisions. We firmly believe that our active stewardship framework
can generate meaningful change and add value over an average three-year period, with formal
assessments carried out, at a minimum, on a yearly basis. However, some areas may necessitate
a longer-term commitment, for which we are wholly prepared. The idea that "investing forthe long-term is an advantage" is a core tenet of our investment philosophy. Every client is ina position to benefit from our long-term investment focus as well as our holistic responsible
investment strategies.

1. Tailoring our approach to client needs ssdfqfddc
AUM by client segment, asset class and region at 31st December 2022
Breakdown of AuM as at 31/12/2022

Joint ventures

16%

Crédit Agricole andSociété Générale
insurance mandates

22%

Employeesavings

Real and
Alternative Assets

Frenchnetworks

6%

International
networks

8%

Corporate

5%

Passive
Management

Third-party
distributors

24%

By client segment

Europeexcl. France
and Italy

18%

Joint ventures€1,904bn

2%

15%

Institutionals
and Sovereigns

9%

15%

Structured
Products€1,904bn

4%

5%Treasury
Products excl.
Joint Ventures

16%

Italy

10%

€1,904bn

ActiveManagement

53%
By asset class

By region

Source: IPE "Top 500 Asset Managers" published in June 2022, based on assets under management as at 31/12/2021.
Among traditional asset managers - Source: Refinitiv, December 2022.
Amundi data as at 31/12/2022.
Assets under management include assets advised and marketed and take into account 100% of assets and inflows from
Asian joint ventures.
For Wafa in Morocco, assets are reported on a proportional consolidation basics.

As we deal with distributors and not end clients, we have limited visibility on end clients who own
our funds and tracking distributors geography would be misleading. This is why we do not give a
breakdown of our clients by geographical area, but only by AuM for client segment or geography.

48 Stewardship Report 2022

October 2023

a. Overview of our Responsible Investment and ESG approach
For a more comprehensive review of our ESG
rating system and exclusionary approach, pleaserefer to Principle 7 of this report.
Our commitment to ESG integration isdemonstrated
throughourproprietaryscoring system, which assesses issuers on amultitude of factors, resulting in a well-rounded
understanding of each company’s sustainability
profile.
Thiscentralised
ESG
scoring
methodology is grounded in universal principles
like the United Nations Global Compact andthe Organisation for Economic Co-operation
and Development’s (OECD) guidelines. With
ratings updated monthly, this scoring systemacts as a comprehensive, sector neutral ESG
performance metric for over 18,000 issuers,
both corporate and sovereign. Our shareholder
engagement approach applies across all ourassets under management, including passively
managed funds.
In addition to our scoring methodology, weapply a sectoral exclusion policy for all actively
managed portfolios where we exercise full
discretion. In accordance with our A-G scale,issuers that we deem the lowest quality, rated
G, are eliminated. In 2022, we completed
divestment from companies that conduct morethan 30% of their business in unconventionalhydrocarbons, in line with our “Ambition 2025”
plan. We are also committed to phasing out
investments in thermal coal by 2030 in OECD
countries and by 2040 in non-OECD countries.
These policies are automatically included ineach new mandate or dedicated fund, unlessotherwise requested by the client.

b. Our Responsible Investment assets under management
Type

Unit

2022

2021

2020

Total assets undermanagement

Total assets under management€ billion

1,904

2,061

1,729

Responsible
Investment assets

Assets under management€ billion

799.7

846.9

378.3

Responsible investment assets inpassive management€ billion

111

95

NA

%

27%

NA

NA

Impact solution assets€ billion

8.7

NA

NA

Amundi Finance et Solidarité fund assets€ million

481.0

440.0

331.0

Amundi Immobilier assets labelled SRIs

€ billion

16.0

15.8

NA

Proportion of ESG ETFs in total number of ETFs

As of the end December 2022, Amundi managedc. €800 billion worth of responsible investment
assets. The scope of Amundi Responsible
Investment AUM reporting consists of investment
products incorporating “Responsible” criteria
into their investment process. The “Responsible”
criteria relate to specific Environmental, Social
or Governance issues, Ethical or Sustainable
themes7, or to a combination thereof.

In order to cater to the diverse ESG preferencesof our clients, we offer solutions in the following
areas:
Broad ESG integration solutions:
Our portfolios consider E, S, and G criteria
alongside traditional financial analysis to fulfil
a wide array of clients’ responsible investingneeds, objectives and motivations. Positioned

7. For instance related to the Sustainable Development Goals developed by the UN (https://sdgs.un.org/goals)

49 Stewardship Report 2022

at the heart of our ESG offerings, most ofthese solutions adopt a best-in class approach,selectively choosing issuers with superior ESG
practices. Additionally, many of our individual
products and fund families feature enhanced

October 2023

ESG integration through methods such as higher
selectivity or indicator upgrade (rating or nonfinancial) should it be on geographic universe orthematic ones.

➜ Our progress in 2022
In 2022, Amundi made significant strides in expanding both our active and passive responsible
investment solutions, aligned with our “Ambition 2025” plan. The key developments include:– Launching the Amundi Fund Euro Corporate Short Term Green Bond, open to both
institutional and retail investors,– Extending the ESG Improvers investment range to include strategies for Emerging Markets
and the US,– Our fully-owned subsidiary CPR Asset Management introduced CPR Invest – Blue Economy,an actively managed fund focused on the marine economic ecosystem,– Collaborated on Quantalys Sélection Thématique (Quantalys Thematic Selection), athematic allocation offering tailored for financial advisers,– Introduced a range of global ESG sector ETFs covering various market segments,– Launched the first ESG ETF on Italian blue chips.
These initiatives contribute to progress towards our “Ambition 2025” goal to have 40% ofAmundi's ETF product range ESG-focused by 2025. At the end of 2022, 27% of the ETF range
is composed of ESG funds.

Sustainability themed investment solutions:
We offer thematic and impact-oriented
portfolios, including:– Paris-Aligned or Climate Transition (PAB/
CTB) index solutions,– Just Transition climate solutions,– Green, social and sustainability bond funds,– Green infrastructure/debt.

Several of these initiatives were developedin partnership with key public and privateorganisations. Further detail can be found below.

50 Stewardship Report 2022

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➜ Our progress in 2022 - Special initiatives and partnerships
Amundi has also strengthened our offering through innovative partnerships and the launch of
Net Zero Ambition investment products, through collaborations with:– the International Finance Corporation (IFC)– the Asian Infrastructure Investment Bank (AIIB)– the European Investment Bank (EIB)
The output was three specialised funds aimed at financing the global energy transition. We
further implemented our Net Zero commitments in 2022 with new investment products suchas:
– Amundi Net Zero Ambition Global Corporate Bond Fund: Launched in November 2022,
this fund invests in bonds from companies worldwide committed to a Net Zero trajectory. It
aims to steer the entire real economy towards carbon neutrality by investing in sectors thatare actively engaged in climate action.
– Amundi MSCI ACWI8 SRI PAB9 ETF Fund: This new listing expands Amundi’s range of
Climate ETFs, replicating an index that is aligned with the Paris Agreement’s goals.
– Amundi European Net Zero Ambition Real Estate (ENZA RE) Fund: This is a real estate
impact fund fully committed to achieving carbon neutrality by 2050. The fund guarantees
that the carbon trajectory of its assets will remain below the 1.5°C trajectory set by the
CREEM benchmark.
These developments collectively reflect our unwavering commitment to responsible investingand ESG integration, and contribute to progress to the targets laid out in the “Ambition 2025”
plan. See Principle 1 for more detail on the “Ambition 2025” plan.

c. Understanding and responding to client needs
Amundi prioritises fostering close relationships
with our clients, ensuring a thoroughunderstanding of their needs and, whereappropriate, tailoring products. Our range of
responsible investment solutions is designed
to meet a wide variety of client preferences,including strategies such as negative screening,
best-in-class screening, norms-based screening,sustainability-focused investing, and impact
investing.
Feedback is formally collected from clients inorder for us to continually improve the qualityof the advisory and training services that we
provide.

8. All Country World Index
9. Paris Aligned Benchmark

We have also worked closely with clients todevelop appropriate products to meet totheir climate change investing needs. We
have, therefore, 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, andmonitoring of their efforts to integrate climatechange into their investment approaches. Thishas been centred around two major goals whenit comes to constructing climate change related
investment solutions: managing risks andencouraging the transition.

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Stewardship Report 2022

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This table shows the main strategies that we developed alongside our clients:
EquityAlign Investments
to a Net Zero
Trajectory

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

We seek to align out engagement activities withthe major issues and priorities facing our clients,
in order to be the best stewards of their capital.
In 2022, Amundi engaged with issuers across
six main areas:– The transition towards a low carbon
economy,– The natural capital preservation (ecosystem
protection & fight against biodiversity loss),– The social cohesion through the protection of
direct and indirect employees, promotion ofhuman rights,– Client, product and societal responsibilities,– Strong Governance practices that strengthen
sustainable development, and– Dialogue to foster a stronger voting exercise
and a sounder corporate governance.

More detail on our engagement approach andactivities in 2022 can be found in Principle 9.

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Stewardship Report 2022

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Illustration 12: Accompanying clients on their Net Zero journey
In 2022, Amundi remained proactive companions for two major European insurers on their Net
Zero journey, a collaborative venture that kicked off in 2021, by:– Assessing portfolio standpoints vs. pre-determined Net Zero targets,– Engaging with the top 20 highest carbon footprint contributors within one insurer’s
portfolio, and– Pursuing advisory on Net Zero and NZAOA requirements.
We also engaged with an additional large European insurer about their Net Zero journey by:– Supporting the client's decision to embark on a Net Zero journey:- Introducing our client to leading Net Zero initiatives,- Conducting a Net Zero Benchmarking & peer review, and- Providing a full assessment of the recommended Net Zero initiative’s protocol.
– Agreeing on governance at asset owner and at asset manager level:- Helping our client to define its Net Zero framework: what, where, when, how?
- Define a fit for purpose governance to monitor Net Zero objective at both SAA and Strategy
level.
Following this, we will pursue our advisory mission by supporting their implementation,
monitoring and engagement strategy.

Illustration 13: Accompanying client understanding of their Climate risks
In 2022, Amundi conducted a review of available transition and physical risk metrics, notably
using climate scenarios to answer requirements from new regulations. Amundi was able toidentify and deploy new metrics to measure the transition risk exposure of clients' portfolios.
Those metrics were used notably to meet the expectations of the French regulation LEC29
and TCFD requirements.

➜ Our progress in 2022
Identifying and responding to institutional clients’ needs
In 2022, the results from our annual clients’ survey highlighted the need to strengthen further
the dissemination of our ESG thought leadership. Amundi has strengthened the transfer ofintellectual capital to its clients by intensifying the production of our series of ESG Thema,a short document on responsible investment issues and their consequences. Through its
targeted communication efforts, Amundi has further highlighted its leadership in responsible
investment and its wide and diversified range of investment solutions. In 2022, we published
7 ESG Thema including two special editions for COP15 and COP27 and a thematic research
paper series on biodiversity, as well as two dedicated papers on ESG integration in credit andthe green risk premium.
These papers are now part of the most consulted publications within Amundi Research Center,
proving that there is a clear interest from clients and the financial industry at large to stay
informed on rapidly evolving ESG topics.
Our commitment to client-centric stewardship remains unwavering. As part of our dedication,
we have instituted clear contractual relationships with clients that clarify our responsibility
to deliver on ESG and stewardship mandates. We work diligently to meet and exceed theserequirements.

53 Stewardship Report 2022

October 2023

2. Responding to risks and global crisis ________
Risk management continues to be pivotal to
our stewardship approach. Recent years havebrought significant challenges, such as a healthand geopolitical crisis. The Covid-19 pandemic
was a global event without modern precedent,
which became an economic crisis that wasreflected in the sharp drop in asset prices andan increased volatility on financial markets.
Amundi managed the crisis and continued
normal operations thanks to the actions taken
in terms of risk management, human resources
and IT to monitor the liquidity of our portfolios.
Plans implemented in the early stages of thepandemic enabled all Group employees to work
remotely or on site, as appropriate, under safe
and secure conditions. These rules and policies
were amended and adapted as restrictions werelifted during 2022. At all times, our priority wasfor the health and safety of all employees andensuring a continuity and consistency of client
service and communication.
The Russian invasion of Ukraine in February
2022 was one of the year’s most significant
geopolitical events. In addition to bearing
witness to the unfolding human tragedy,
Amundi took very seriously our responsibility tokeep our clients informed about any exposure
to or enhanced risk stemming from the conflict.
More details on Amundi’s approach to marketwide and systemic risk can be found in
Principle 4.

3.Reporting openly and transparently to our clients
Amundi welcomes the opportunity to be fullytransparent and open with our clients, and we
maintain clear channels of communication. This
includes providing investors with a wealth of
documentation on our Responsible Investment
approach, Engagement and Voting policies

and reports and other ESG-related reports.
Further, Amundi is able to provide both genericand customised ESG reporting depending on
individual client needs. A list of the documents
available and sample reporting in the Appendix.

➜ Our progress in 2022
In 2022, Amundi published its updated Climate and Sustainability report with a twofold
objective:– To report on the group's sustainable investment strategy and the objectives that have been
defined in order to carry the ambition further.
– To report on the implementation of this strategy: the governance and the operational
system put in place for its deployment, the means and actions deployed, and finally the
associated results.
– Starting this year, the report is made up of two sections:– The LEC11 29 report, which meets the requirements of Article 29 of the French Energy andClimate Law and the recommendations of the Task Force on Climate-related Financial
Disclosures (TCFD).
– The PAI report, which is the consolidated statement of Principal Adverse Impacts (PAI)
for all Amundi Asset Management French entities, measuring each PAI indicator and ouractions to mitigate them.

11. Loi Energie Climat

54 Stewardship Report 2022

October 2023

Principle 7
Signatories systematically integrate stewardship andinvestment, including material environmental, social andgovernance issues, and climate change, to fulfil their
responsibilities
The ESG challenges that companies face have a significant impact on society. Moreover, they
carry financial implications, presenting both risks and opportunities for businesses. At Amundi,
our objective is to better understand these ESG-related opportunities and risks, weaving theminto our investment strategies on behalf of our clients.
This section elaborates on how ESG criteria are incorporated into our management processesfor ➊ corporate listed assets, ➋ sovereign debt issuers, ➌ real assets as well as ➍ delegatedfunds.
In addition to ESG analysis, Amundi adheres to a strict exclusionary policy, which we continually
evaluate and evolve. Further detail on progress in 2022 can be found in this Principle.
Finally, we provide an overview and progress update on our “Say on Climate” strategy.

1. ESG analysis consolidates value creation_____
Amundi is steadfast in our conviction thatcomprehensive ESG analysis fortifies value
creation by providing a holistic understandingof a company. This perspective guides ourdecision to weave ESG criteria across our active
management processes, and to maintain an
active engagement policy.
At the heart of our ESG integration is the belief
that robust sustainability policies empowerissuers to better navigate their regulatory
and reputational risks, while simultaneously
improving their operational efficiency. This
integrated approach enables investors toanticipate long-term risks – be they financial,
operational or reputational – and fully exercise
their fiduciary responsibilities to clients and thebroader society.

Amundi’s ambition, through our ESG analysis, isto raise awareness and spur companies towards
a sustainable operational ethos, which is thenreflected in our ESG ratings. This analyticalperspective allows us to assess risks in line witha company's operations, reducing the overallrisk exposure for our clients. Consequently, weclosely monitor our investee firms across all ESG
criteria and traditional financial indicators. Our
objective is to promptly identify potential issues
so we can prevent or limit any adverse effects
on the financial well-being of both the company
and our clients.

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October 2023

2. A proprietary ESG rating available to all portfolio
managersa. Overview of the ESG rating
ESG analysis is the responsibility of the Responsible Investment team and is integrated into Amundi’s
portfolio management system. It is available in real time in the tools used by portfolio managers,
to provide them with immediate access to the ESG scores of corporates and sovereigns, as well as
financial ratings.

1. Criteria & Weights
ESG analysts:– Define the most relevant criteria
for each sector based on ESG
materiality– Weight the criteria by sector
and select the appropriate datafrom each provider selected

2. ESG rating calculation
The Global Data management
team carries out a strict
calculation procedure:– ESG ratings calculation processby combining Amundi's criteria
and weights with external
providers' scores– Contribute to the assessment of
the quality of our external data

– Quality control of the calculation

Qualitative Approach

Quantitative Approach

3. Qualitative input
ESG analysts integrate qualitative
input retrieved from:– Meetings with companies &industry experts– ESG data/research from external
providers and open-source
materials– Updated monthly+18,000 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 December 2022

Amundi has defined its own analytical frameworkand developed its ESG rating methodology,
the latter of which is both proprietary andcentralized, which promotes a consistent
approach to responsible investment across theorganisation, in line with Amundi’s principles
and priorities.
The ESG rating aims to measure the ESG
performance of an issue; for example, its ability
to anticipate and manage the sustainability risks
and opportunities inherent to its sector andparticular situation. The ESG rating also assesses
the ability of the company’s management toaddress the potential negative impact of theiractivities on the sustainability factors that may
affect it.
Portfolio managers and analysts from Amundi’svarious management platforms have permanent
access to the issuers’ ESG ratings, as well as
related ESG analyses and metrics. Currently,
more than 18,000 issuers have been given an
ESG rating.
Our ratings span from A, indicating the best,
to G, the lowest. Barring a few instances (somepassively managed portfolios or client specificmandates) G-rated issuers are excluded from all
portfolios.

56 Stewardship Report 2022

October 2023

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).

We ensure that issuers are continually monitored,with any controversial developments includedin the ESG analytical process. A controversy
can lead to a change of rating – this could
reflect a specific criterion or even result inan adjustment of the final ESG score. For thesake of transparency, we have implemented
our proprietary Stock Rating Integrator tool.
This tool facilitates a clear understanding of
an issuer's rating at any given time, portrayedthrough a 'flower graph', which clarifies thescores based on diverse criteria.

Example of an ESG rating of accompany as displayed in the Stock rating Integrator
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

57

Stewardship Report 2022

In addition to the routine calculation of ratings,
our ESG analysts undertake an active and indepth analysis of issuers flagged for review.
Various triggers can prompt intensified scrutiny,such as:– Direct requests from portfolio managers,

October 2023

– Our annual engagement campaigns,– Issuers with a particularly weak ESG rating
for a given criterion, and– The quarterly controversies screenings.

– The overall level of exposure of Amundi to agiven issuer,b. Dedicated expertise provides the highest value to the clients
The Responsible Investment team functions
autonomously, while still maintaining a close
collaboration with the Investment Management
and Financial Analysis teams. This structure
not only ensures the impartiality of our ESG
analysis, but also rigorous oversight as all
G-rated issuers undergo validation by the ESG
Rating Committee either directly or through theexclusion process. The separation of the ESG
analysis allows our portfolio managers to benefit
from different skills sets – both from financial
and ESG perspectives – allowing them to maketheir investment decisions independently. With
the exception of G-rated issuers, investment
decisions regarding specific issuers securities
ultimately rests in the hands of our portfolio
managers.

We believe this structure provides the highest
value to our clients, who can leverage the
combined strengths of our ESG, Financial
Analysis and Investment Management teams.
Furthermore, Amundi emphasises our active
engagement strategy as an essential part ofour Global Responsible Investment Policy.
Through these engagements, our goal is to use
of ESG ratings to guide companies towards
improvement, amplifying their real-world impact
and subsequently expanding the investment
options available to our managers and clients.
Further detail on the structure of and dedicatedresource within the Responsible Investment
team can be found in Principle 2.

3. ESG analysis and rating across asset classes ___a. Amundi proprietary ESG rating at company level, applying to both
listed equity and debt
ESG ratings are applied by the dedicated
ESG Method and Solutions team. Our ratings
approach is at the company level, encompassing
both equity and fixed income instruments
alike. Central to this strategy is our firm belief
in double materiality: the negative real-world
implications of an issuer's actions remain ofparamount importance, irrespective of thefinancial sensitivity of the asset in question.
As is previously referenced in Principle 2, ourmethodology is based on 38 criteria; including 17
generic criteria, which are common to all sectors,

and 21 specific criteria, which are relevant to thechallenges of the various sectors. ESG ratings
are updated on a monthly basis, using raw data
provided by our external suppliers. The ESG
Research Team closely monitors changes inissuers’ ESG practices. ESG analysts regularly
adjust their analysis and rating methodology inline with the environment and any event that
may affect it.

58 Stewardship Report 2022

October 2023

Overview of criteria assessed in ESG analysis framework

CROSS-SECTOR
CRITERIA

Environment

Social– Emissions & Energy– Water Management– Biodiversity & Pollution– Supply Chain Environment– Health & safety– Working Conditions– Labour Relations– Supply Chain - Social– Product & Customer
Responsibility– Community
Involvement & Human
RightsEnvironment
SECTOR SPECIFIC
CRITERIA

The ESG Method and Solutions team is
responsible for assigning ESG ratings. For
each sector, ESG analysts weigh 4 to 5 sector-– Board Structure– Audit & Control– Remuneration– Shareholders' Rights– Ethics– Tax Practices– ESG Strategy

Social– Clean Energy– Green Car– Green Chemistry– Sustainable Construction– Responsible Forest Management– Paper Recycling– Green Investing & Financing– Green Insuring– Green Business– Packaging

Every portfolio manager has access to theseratings, and the calculations of the 38 criteria that
inform them through our investment portfolio
management software tool. This accessibility
ensures that sustainability considerations are
woven into their investment decisions, withportfolio managers applying any relevant
constraints for their portfolios as applicable.

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

specific criteria deemed the most important.
Analysts will typically increase their level ofscrutiny whenever the risk faced by a company
on any given ESG criterion is deemed highand material. There is only one ESG rating foreach issuer, regardless of the chosen reference
universe. The ESG rating is thus ‘sector neutral’,ensuring that each issuer is evaluated evenly,
with no sector receiving undue advantage ordisadvantage. The culmination of these efforts
results in an ESG rating spanning from A to G.

Breakdown of environmental criterion
in the automotive sector

1%

E

S

Water management

G

3%
25 %

Automotive
Banking
Telecom

40%
24%
15%

34%

26%

29%

47%

53%

32%

Green
car

Emissions & Energy

3%

Supply Chain –Environment

8%

Biodiversity& Pollution

59 Stewardship Report 2022

October 2023

Example of sector weight attributions
Our dedication to quality is unwavering, andwe continually refine our analytical processes,
always mindful of the relevance and weightof each criterion. Our ESG analysts are sector
specialists who are committed to:– Tracking trends (macroeconomic, regulatory,etc.),– Establishing weights based on the materialityof ESG factors,– Assessing a representative panel ofcompanies,– Selecting the most qualified external data
suppliers meeting the definition of ourcriteria, and– 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.
While our core approach is consistent, we
modify where necessary to service different
asset classes to reflect their unique impacts.

– Writing sector analysis reports,➜ Our progress in 2022 - Consideration of environmental transitionin the analysis
As part of our “Ambition 2025” plan, Amundi announced that we want to further integrate nonfinancial objectives related to climate into our active portfolio management. We are therefore
working on the implementation of a rating methodology in order to assess, via a best-in-classapproach, the transition efforts of issuers in relation to a Net Zero scenario, specifically throughthe effort made to decarbonise their business and develop their green activities.
All managers have access to the ESG ratings and analyses of the companies concerned, anduse them in their own way depending on the management process. For example, different
management platforms have developed alpha generation approaches based on the prospectsof improving the ESG profile of invested companies.

b. Sovereign debt assessment
In addition to corporates, we also assess the
ESG performance of sovereign issuers, on theunderstanding that ESG factors can significantly
influence an issuers ability to repay its debt
in the mid- to long-term, thus representing arisk for investors. These factors also serve asa reflection of how countries handle the major
sustainability issues that are pivotal to global
stability.
Our methodology is anchored on roughly 50 ESG
indices or factors, which have been identified
by Amundi ESG research as pivotal to tacklingsustainability risks and issues. The indicators
are obtained from an independent provider andeach indicator may combine several data points,

drawn from different sources, including open
international databases (such as those of theWorld Bank Group, the United Nations etc.) or
proprietary databases.
The indicators are grouped into eight categories
for greater clarity, with each category falling into
one of the E, S or G pillars. As with the corporate
ESG rating scale, the ESG analysis of sovereignissuers is translated into an ESG rating ranging
from A to G.

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Environment

SocialGovernance

Climate Change
Natural Capital

Human Rights
Social Cohesion
Human Capital
Civil Rights

Government
EffectivenessEconomic
Environmentc. Green, Social, Sustainable and Sustainability-linked (GSS+) Bond
analysis
The GSS+ Bond Analysis team within the Amundi ESG Research, Engagement & Voting team is incharge of defining the investable universe on the GSS+ bond market. Utilising our internal GSS+
bond assessment, any new investment must be evaluated. It is important to note that portfolio
managers are not allowed to trade GSS+ bonds that have not first been screened by GSS+ bondanalysts.
Amundi developed our GSS+ bond assessment process to ensure that we are appropriately
evaluating the relevance and the extent of the impact of the projects financed by the proceeds ofthe GSS+ bonds we invest in. We also assess the alignment of the issuer’s ESG strategy with its GSS+
bond issuance. Prior to investment, all GSS+ bond investments undergo a three-step assessment:
1. Issuer-level ESG screening
The GSS+ bond analysts systematically check for the following:– Alignment of issuer with industry standards (e.g. ICMA Green or Social Bond Principles, EU
taxonomy),– Existence of a second party opinion or other certification, such as Climate Bond (CBI)
certificates,– Whether the issuer faces severe ESG controversies (detailed in section 7. ‘Amundi’s Responsible
Investment Capabilities & Resources’); and– Whether the projects to be financed by the green bond contribute to wider efforts by the issuer
to favour the energy and/or environmental transition.
If this initial screening is not satisfactory, then the GSS+ bond cannot be considered for investment.
2. Issuance-level GSS+ analysis
Once the GSS+ bond issuer has undergone the initial screening, Amundi GSS+ bond analysts
conduct a comprehensive review of the GSS+ bond issuance and a comparative analysis of the ESG
performance of the issuance versus the overall ESG strategy of the issuer, as follows:
Green & Social
Funding Rationale

Project
Asset level Impact
Degree of green &social contribution inabsolute, as well as relative to the sector andthe country

IssuerIssuer strategy
Contribution to issuer's
ESG strategy, link
between the green/social bond and issuer's
KPIs

Source: Amundi, provided for illustrative purposes only.

Funding purpose
Alignment between
green/social bonds andgreen/social assets interms of purpose andallocation

Transparency
Disclosure
Amount of information
available on projects,
impact data, andverification

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Stewardship Report 2022

If the analysis concludes that the GSS+ bond is
not investable under Amundi’s eligibility criteria,
portfolio managers are not allowed to buy thebond for inclusion in their portfolios.
3. Ongoing monitoring after investment
After investment, the GSS+ team continues
to assess that an issuer still has coherent ESG
commitments.
– One year after the issuance: assess theavailability of the allocation and impact
report of the GSS+ bond, including a formal
dialogue with the issuer in case partial
information is missing,– On a regular basis: perform a review of theissuer’s environmental and/or social strategy
to ensure that the overall ESG performanceof the issuer is improving and is updated
accordingly in case there is a significant
evolution from one period to another,– On a daily basis: controversy screening
through different channels (internal
controversy database, data providers, press,
emails). If a significant controversy occurs,
the GSS+ bond analyst engages with theissuer.

October 2023

All of the information or data collected in theabove-mentioned actions are gathered into aninternal proprietary GSS+ bond database thatallows Amundi to monitor the investable GSS+
bond universe. All bonds are reviewed once a
year to reflect changes in the data. This internal
database allows us to feed issuer and issuancelevel data at the fund level, which allows for abetter understating of the allocation and impactof the strategy.
This serves as the basis for engagement with
relevant GSS+ bond issuers, during which weseek to:– Clarify discrepancies or missing impact data;such as understanding why there is a missing
impact report, problematic impact data, orto define a remediation plan to address acontroversy,– Encourage issuers to integrate better ESG
practices by promoting ICMA harmonised
framework for impact reporting, promoting
Life Cycle Assessment (LCA) considerations
from the EU Taxonomy, encourage issuers to
set targets for their ESG strategy, improvetheir Environmental and Social policies
See Principle 9 for how we engage on Green
Bonds

d. Real assets
In 2022, Amundi’s Real Assets division
underwent substantial growth, with assets
under management reaching over €66.6 billion
by the end of December. This growth is atestament to our unwavering commitment tosustainable and resilient investment within real
assets, underpinned by a comprehensive andevolving ESG integration strategy.
The advancements made in 2022, which
are further elaborated on in the centralised
Responsible Investment Charter, underscore
Amundi's dedication to refining the Real Assets
division, ensuring an adaptive, multifaceted
approach to ESG integration and effectively
addressing sustainability challenges within all of
our investments.
Strong ESG Governance within Real Assets
division

The integration and oversight of ESG governancewithin the Real Asset division is driven by:– ESG team dedicated to the Amundi Real
Assets platform
This five-person team works very closely withthe management teams and the members ofAmundi Group’s central ESG team.
– Real Assets Management Committee
dedicated to ESG issues
Amundi Real Assets’ Management Committee
includes ESG and impact topics related toreal assets on its agenda at least once every
quarter.
– A Real Estate ESG Committee
The members of this committee represent all
the key functions at Amundi Real Estate (asset
management, ESG analysis, compliance,
management, risks, etc.). The committee
meets quarterly and defines and monitors the62 Stewardship Report 2022

October 2023

entity’s responsible investment strategy andengagements.
– An “ESG Front Runners” community
30 ESG representatives have been chosen fromthe various teams of the Amundi Real Assets
platform (management, ESG analysis, sales,
marketing, legal, etc.) to discuss all common
issues in the field of responsible investment for
the real estate assets areas of expertise. Moregenerally, they have been brought together
to ensure a consistent approach and to drive
collective ambition. Their meetings are a forum
for discussions on regulatory changes and forthe sharing of information and good practices
between areas of expertise.
– Additionally environmental, social andgovernance issues are discussed at all
meetings of the investment committees ofthe six different Amundi Real Assets areas ofexpertise.
– Publication in 2022 of an SRI Charter for
Amundi Real Assets covering the wholeplatform. Publication in July 2023 of thesecond edition of its Responsible Investment
report.

In alignment with the broader Amundi Ambition 2025 plan, the Real Assets division is poised
to implement new commitments and features, underscoring its continuous drive towards ESG
excellence.
ESG 2025 Objectives Purpose
Real Estate– Launch of the net zero strategy in 2022, in particular via the Amundi European Net
Zero Ambition Real Estate fund (ENZA RE)– Target for 2024: 100% of our main service providers will sign the supplier charter– Target for 2024: 100% of our main service providers will be rated by Amundi Real Estate– Each year, the ESG team commits to organising five training sessions for employees

Multi-Management– Preparation of a net zero private equity fund of funds (article 8 SFDR)– Since 2022: all new investments are subject to an ESG rating– Implementation of a proprietary ESG scoring mechanism– Raise an infrastructure fund of funds (article 8 SFDR)– Preparation of a multi-strategy fund of funds (article 8 SFDR)

Private Debt

– Launch of a 2050 net zero transition fund– 100% of new investments will have a carbon footprint assessment and associatedroadmap– 2022: first ESG awareness seminar for portfolio borrowers– Objective for 2023: organisation of the second ESG seminar– Commercial launch of the ACREL 2 real estate debt fund, with a focus on thecontribution to the energy transition

Private Equity– Launch of a 2050 net-zero just transition fund (article 9 SFDR)– 100% response from our holdings to our ESG reporting questionnaire– 100% of our holdings will have an ESG roadmap

Social impact– Launch of 2050 net-zero just transition fundGreen infrastructure– Launch of a 2050 net zero transition fund
– Establish an ESG roadmap with our developers/industrial partners– Entry into force of the responsible investment policy

63 Stewardship Report 2022

Integrating ESG into the Investment Process
Acknowledging the limitations in our central
ESG rating methodology to cover all instruments
and issuers within our investable universes,
Amundi continues to make significant strides indeveloping tailored methodologies for private
equity, private debt, fund of funds, and realestate and specific instruments like green orsocial bonds. These nuanced approaches arealigned in the new Responsible Investor Charter– Real Assets that was published in 2022.

October 2023

to limit the financial risks (regulatory, operational
and long-term reputational) associated withan investment and to fully discharge their
responsibilities.
ESG due diligence is carried out by all sub
asset classes, in collaboration, where necessary,with Amundi's ESG experts. Depending on theassets in question it may include the sending ofquestionnaires, discussions with the company’s
management and reviews of sector studies by
nonfinancial rating agencies.

The central role of non-financial criteria in real
assets– Within Real Estate: the ESG due diligence
carried out on any investment opportunity is
two-dimensional, incorporating:

There are five key stages to applying ESG criteria
within real assets, with some specific nuance for
sub-asset classes as appropriate:- Analysis of the underlying real estate asset,
and• Analysis of the tenant.
– Within Green Infrastructure: in addition to
analysis of the assets, ESG due diligence also
includes:1. Exclusion policy
Amundi Real Assets applies targeted exclusion
rules in line with those set out in the Group’s
exclusion policy. A full list of exclusions can befound in the Responsible Investment Policy andSection 4 of this Principle. The nuclear sector
is also excluded for Amundi Energy Transition
products and solutions.
2. Selection policy
A preliminary assessment ensures that theinvestment team is exclusively concentratingon the sectors permitted under the responsible
investment policy for the category of assets,
the fund or the mandate. Additional exclusions
may be applied in the prospectuses of certain
funds, depending on the strategy. In addition to
the exclusion list, social impact investments only
invest in companies whose primary purpose isto create a positive impact for the intended
beneficiaries of their actions. At each stage ofthe investment strategy, the impact analysis andthe situation of beneficiaries take precedence
over any other decision-making criteria.
3. Due diligence
In addition to the exclusion policy applied
as a first filter, any opportunity received andpresented to the investment committee issubject to ESG due diligence that includes anin-depth analysis of any non-financial risks
identified. This due diligence is an integral partof the analysis criteria and supplements theparallel financial analysis. This enables investors- Analysis of co-investors,- Analysis of the assets’ operator, and- For assets that produce renewable electricity,
analysis of the electricity buyer under B2B(business to business) contracts (other thanoperators mandated by public authorities
to act as references on public requests for
proposals).
4. Investment decisions
The investment decision-making process andthe investment memorandum for each areaof expertise systematically includes the ESG
due diligence results. Each team is particularly
attentive to opportunities and ways of reducing
the carbon footprint of assets.
Amundi Real Assets’ investment decisions
involve two key ESG processes:– Within private equity, corporate private
debt, multi management and social impact
investing: the ESG representative has
the right to veto investment decisions inadvance of or at meetings of the investmentcommittee.
– Within real estate and green infrastructure:
the investment committee ensures thatthe appropriate ESG criteria for the fund inquestion are properly applied before any
investment decision is made.

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Other points to note:– Within private equity, corporate private
debt, multi management, social impact
investing and green infrastructure areasof expertise: at the time the investment ismade, the agreement entered into with theentity in receipt of the financing includes
a commitment on providing ESG data andmeeting objectives, in line with the relevant
fund’s strategy.

into the assessment of environmental andsocial performance.
- Better management of the use of theunderlying asset, reflected by efforts inrelation to the carbon footprint.
– Within Multi Management: an annual survey
is carried out to monitor the progress madeby the portfolio. The team applies a numberof performance indicators that benchmark
developments in ESG practices and metrics.

– For Amundi Real Assets’ impact funds:
intentionality is a key factor, as borne out by
specific analysis for each of the funds that isused for investment theses and investment
decisions.

– Within Corporate Private Debt and Private
Equity: ESG performances are reviewed
annually as part of portfolio monitoring,using indicators chosen in advance with theissuer/investee company and in line with
the ESG information obligations defined in
the contractual documentation. A meeting
dedicated to implementing an action plan
to improve ESG performance is also offeredto each issuer/investee company. Throughtheir seat on the governance committee,
the representative of the private equity
team is able to discuss and monitor material
developments in ESG matters included on
the agendas of committee meetings.

– Within real estate area of expertise: accountis taken not only of the asset's performance,
but also the environmental and social
performance of the main stakeholders in theproperty (property managers, maintenancecompanies, builders, etc.) and any tenants.
– Within multi management: an in-depth
review is carried out on the ESG practicesof the managers of each fund and theintegration of ESG criteria into their decision
making process.
5. Holding period
Where possible during the holding period, each
investment manager or director maintains an
ongoing dialogue with the companies and/or
the managers of the assets held in the portfolio.
This close relationship is used to monitor actionplans and to improve ESG performance. The
management teams have two priorities in termsof responsible investment: a periodic review of
the non-financial performance of the assets intheir portfolio and the production of carbon
footprint assessments.
Each sub asset class has developed practices
specific to its investment universe:– Within Real Estate: the ESG rating isreviewed at least once every three years
during the holding period. This allows us tofactor in the progress achieved on underlying
assets. This progress can be achieved inseveral ways, in particular:- A direct/physical improvement as a resultof work carried out. The results of theseactions are directly transcribed in the annual
questionnaire and the maintenance or
educational actions for tenants, which feed

– Within Social Impact Investing: eachcompany in the portfolio is the subject ofimpact analysis. A series of quantitative
criteria are assessed each year, resulting
in the publication of an impact reportfor investors several times a year, usually
expressed in terms of the number ofbeneficiaries per theme. Monitoring iscarried out throughout the holding period
as well as annually, involving participation
in meetings of strategy committees,
introducing the business owner to ourecosystem and partners, and support with
the implementation of the economic andimpact business plan. At each meeting of thestrategy committee, the results are comparedwith the stated objectives and the impact
made by the company is assessed.
– Within green infrastructure: impact reports
for each fund are published every year withdetails of the environmental, social andgovernance monitoring carried out by thearea of expertise. In addition, each investee
company’s supervisory committee reviews
the assets’ ESG performance every quarter totrack it as closely as possible.

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➜ Our progress in 2022
Our achievements in the 2022 reporting period include:– In January, we drafted an ESG charter common to all six areas of expertise – Real Estate,
Multi Management, Private Debt, Private Equity, Social Impact and Green Infrastructure - wealso published the the inaugural Real Assets Responsible Investor Report,– In March, Amundi Real Assets participated in the Best Practice Guide for Private Debt
Sustainability-Linked Finance published by France Invest, a professional organisation
bringing together nearly 400 French management companies and some 180 consulting
firms,– Launched the Amundi European Net Zero Ambition Real Estate fund in June and theAmundi Delta Capital Health Real Estate Investment Trust in October. The latter dedicatedto the health, well-being and long term care sectors in Europe,– In September, Amundi Real Assets organised the first ESG meeting dedicated to the small
and medium-sized companies that ARA supports in private equity and private debt. This
first meeting was dedicated to ESG and focused on the theme “What role should ESG play
in today’s small and medium-sized companies". It brought together almost 50 leaders from25 small and medium-sized portfolio companies,– We celebrated the tenth anniversary of the Amundi Finance & Solidarity social impact fundwith almost €500 million of assets under management.
– Published a Cahier de Vacances (Holiday Issue) in Summer 2022 – an educational initiative
to help employees and partners understand responsible real estate investment. It was
distributed to nearly 120,000 people,– The ESG Front Runners team was renewed and expanded, adding four more members.

Specific progress in 2022 for Private Debt
– In March, Amundi Real Assets made significant strides in bolstering our ESG integration
within the Private Debt sector,– Participation in market working groups centred on Sustainability-Linked Loans. These
efforts culminated in the release of a reference guide at the end of 2022, outlining the ESG
aspirations we intend to champion with such financial tools,– The fourth private corporate debt round emphasised an impactful strategy, seeking
to equip each issuer with a tailored carbon footprint and an action plan for emission
reductions,– Launched a refined ESG reporting format, offering our fund investors a richer dataset andin-depth analysis, underscoring our commitment to transparency,– Through collaboration with the ARA and Amundi Real Estate ESG teams we have facilitatedenhanced integration of Sustainable Finance Disclosure Regulation (SFDR) concerns,
ensuring our tools and strategies align with current regulatory expectations.

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e. Delegation of fund management to third parties
Amundi sub-contracts the management of €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%).

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. Boththese qualitative and quantitative evaluationsof a manager’s approach to ESG are part ofa broader due diligence process of the fund/mandate and the company (operational due
diligence, quality of investment process, qualityof teams, performances, etc.).
When we delegate funds to managers, we
also send them monthly a list of stocks to be
excluded. When Amundi just performs a fundhosting function, then the exclusion list does notnecessarily apply.

Illustration 14: 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.
4. Portfolio construction
When constructing solutions for clients, fund of fund portfolio managers seek to “Beat theBenchmark” in terms of their ESG Score. To do this they use:
1. The “look through” or “transparency” to underlying securities feature that is available
in our front office system, Alto, to score internal Amundi funds and delegated funds andmandates for ESG,
2. For ETFs, the ESG score of the reference index of each ETF is used as a proxy,
3. The ESG score for external funds (per section 2 above) is integrated in Alto.

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4. Exclusionary approach ___________________
a. A targeted exclusion policy
Amundi applies a strict exclusion policy of theworst ESG-rated companies across all actively
managed portfolios, in line with our fiduciary
duty to guard clients’ interests. We ensure
the strict exclusion of issuers not adhering toestablished sector policies or those in violationof international conventions, frameworks, andnational regulations. Our exclusion policy is
kept under active consideration and is formallyreviewed annually and approved by the ESG
Committee. The current exclusion policy bars
any of our funds from investing in:– Issuers involved in the production, sale,storage or services for and of anti-personnel
mines and cluster bombs, as prohibited by
the Ottawa and Oslo treaties,– Issuers involved in the production, sale orstorage of chemical, biological and depleted
uranium weapons,– Issuers that repeatedly and seriously violate
one or more of the 10 principles of the Global
Compact.
Additionally, Amundi applies specific sectoral
exclusions to controversial industries, namely
coal and tobacco. As of the end of 2022, thisalso extends to the unconventional oil and gas
sector as well as the nuclear weapons industry.
These sectoral exclusions are applied to all
actively managed strategies over which Amundi
has full portfolio management discretion, always
adhering to relevant laws that may prohibit theirimplementation.
These exclusions apply unless clients specificallyrequest otherwise in the context of individual
mandates or tailored funds, or entirely passive
strategies.

Illustration 15: Sectoral exclusions policy
Thermal Coal12
Amundi continues to strengthen our commitment to reduce coal exposure in portfolios,
underlining the persistent drive towards exiting coal by 2030 in OECD countries and by 2040
globally, congruent with the United Nations Sustainable Development Goals (SDGs) and the2015 Paris Agreement (see Principle 9 for more details on specific engagement on coal). This
strategy builds on the insights and suggestions of the Crédit Agricole Scientific Committee,
referencing scenarios by the International Energy Agency’s (IEA) Sustainable Development
Scenario, Climate Analytics Report, and Science-Based Targets. Annually enhanced since 2016,
the exclusion criteria have been further tightened.
Where applicable, Amundi excludes:– Mining, utilities, and transport infrastructure companies that are developing coal projects
that have permitted status and are in the construction phase as defined in the coaldevelopers list of the Crédit Agricole Group.
– Companies with coal projects in earlier stages of development, including announced,
proposed, with pre-permitted status, are monitored on a yearly basis.
For companies considered too exposed to be able to phase out from thermal coal at the rightpace, Amundi excludes:– All companies with revenue in thermal coal mining extraction and thermal coal power
generation >50% of their revenue without analysis,– All coal power generation & coal mining extraction companies with a threshold between
20% and 50% with a poor transition path13.
Concerning mining extraction, Amundi excludes:– Companies generating >20% of their revenue from thermal coal mining extraction– Companies with annual thermal coal extraction of 70MT or more without intention to
reduce.
12. For more information see Amundis’ RI policy
13. Amundi is performing an analysis to assess the quality of their phase out plan

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➜ Our progress in 2022
In 2022, Amundi further enhanced the rigor of our Thermal Coal Exclusion criteria. Here are thekey improvements:– Amundi excludes all companies generating more than 20% of their revenue from thermal
coal mining extraction compared to 25% in 2021.
– Amundi also excludes all companies extracting more than 70 Mt thermal coal annual withno intention to reduce compared to 100 Mt in 2021.
Amundi has fortified our engagement approach in 2022, ensuring all companies with thermal
coal exposure are actively engaged and encouraged to align with our phase-out policy andtimeline. Clear consequences for non-compliance have been outlined, including voting against
the re-election of board or management members of firms not adhering to the phase-out
timeline. These updates in 2022 emphasise the policy's robustness, contributing significantly
to global decarbonisation efforts and alignment with worldwide climate goals.
Tobacco– As a signatory of the Tobacco Free Finance Pledge, in 2022 we further strengthened our
tobacco exclusion policy to align with global health and human rights priorities, to address
the significant economic and societal costs related to tobacco use, estimated at over $1
trillion annually by the World Health Organisation14 This policy applies comprehensively
to the tobacco sector, including suppliers, cigarette manufacturers, and retailers. It isapplicable across all actively and passively managed ESG strategies over which Amundi
has full discretion. We exclude companies that manufacture complete tobacco products,
applying a revenue threshold of 5%.
– The ESG rating of the tobacco sector is firmly capped at E. This policy applies to companies
involved in the production, supply, and retailing of tobacco with revenues above 10% and is
meticulously enforced on active investments.
Exclusions are seamlessly integrated into Amundi's investment tools, with the Risk BusinessLine ensuring robust enforcement of the policy. Should there be residual exposure to companies
within the exclusion policy’s scope, Amundi will vote against the board or management’s
discharge or re-election. Utilising MSCI as a data provider, we ensure extensive and reliabledata back our policy enforcement.
Our enhanced tobacco policy is a testament to our enduring commitment to reducing exposure
to the extensive risks within the tobacco sector.
Unconventional oil and gas
By the end of 2022, Amundi also excluded companies whose activity is exposed to explorationand production of unconventional oil & gas extraction (covering “shale oil and gas” and “oilsands”) by over 30%. This is in line with Amundi’s “Ambition 2025” plan.
Sovereign issuers exclusions
Countries on the European Union (EU) sanction list with a sanction consisting of asset freezing,
and a sanction index at the highest level (considering both United States and EU sanctions) areexcluded, after formal review and validation from Amundi’s Rating Committee.

14. https://www.hrw.org/report/2014/05/13/tobaccos-hidden-children/hazardous-child-labor-united-states-tobaccofarming

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➜ Our progress in 2022
In 2022, Amundi also introduced new exclusion criteria. The updated exclusions now include:– Issuers engaged in the production, sale, or storage of nuclear weapons for countries notparty to the Treaty on the Non-Proliferation of Nuclear Weapons,– Issuers involved in the production of nuclear warheads and/or entire nuclear missiles,– And issuers generating more than 5% of their total revenue from the production or sale ofnuclear weapons.
These issuers are classified as G-rated according to Amundi’s rating system, reflecting ourcommitment to mitigating investment risks associated with nuclear weapons production andsale.

Case study 5: A combined engagement approach with governments, utilities andbanks in Indonesia to facilitate our disinvestment from thermal coalContext: Amundi has committed to reduce our exposure to thermal coal in our portfolios, witha formal exit for OECD and EU countries by 2030 and for the rest of the world by 2040, inline with the Paris Agreement. This commitment to such deadlines does impact our capacity
to invest in issuers exposed to thermal coal, including utility companies. However, we dorecognise that companies are constrained by the legislative framework and energy policiesof the countries in which they operate, and that any energy transition should consider energy
security and affordability.
Amundi Actions: We have initiated joint engagement with utility firms, governments, andfinancing banks to navigate towards a low carbon energy mix. Targeting countries withsignificant coal reliance for power generation, with Indonesia being one of those countries, we
aim to align our sovereign and thermal coal policy engagements. We contacted the Indonesian
Ministry of Finance in late 2022 to further this objective.
Key objectives:– Explain our thermal coal engagement and the impact on issuers, notably utilities,– Obtain clarifications on Indonesia’s thermal coal phase out plans and discuss ways to bringforward the target date from 2050 to 2040, and– Discuss ways for the government to support the energy transition of utility companies.
Outcomes & Next Steps: Indonesia has pledged to achieve net zero GHG emissions by 2060
and enhanced its Nationally Determined Contribution in September 2022. Additionally, a Just
Energy Transition Partnership was agreed with a group of developed countries in November
2022, with the aim to expedite the adoption of renewable energies. Despite these commitments,
Indonesia’s 2021-2030 Electricity Supply Business Plan anticipates a 14 GW increase in coalfired generation fleet, a rise of 40%. A Presidential Regulation published in September 2022
outlines a 2050 phase-out target for coal power, diverging from the 2040 target deemednecessary to adhere to the 1.5°C temperature limit as indicated by the IPCC and IEA.
Our engagement letter underscored the discrepancy between Indonesia’s decarbonisationcommitments and the pathway consistent with the Paris Agreement's objectives. Moving
forward, we propose a discussion with the Ministry of Finance regarding this issue and willcontinuously support and monitor the acceleration of their energy transition. A significant
aspect to clarify is whether the Joint Energy Transition Partnership will alter the plans forincreased coal power capacity and aid in advancing the thermal coal phase-out target date.

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Case study 6: Responding to emerging controversies at a European chain of nursing
homesContext: The issuer, a French and European leader in the private for-profit nursing home sector,
faces a lot of controversy regarding unethical behaviour, toxic culture and governance issues.
Detailed investigations revealed issues like fraudulent work contracts, embezzlement of publicfunds, potential conflicts of interest with the Ministry of Health and tax evasion. These issues
have limited the group’s ability to provide adequate staffing and medical care, and accusationsof a management style based on “terror” have further exacerbated the situation.
Amundi Actions: We have actively monitored and engaged with the company over the
past decade, due to persistent issues that seemed more pronounced than for their industry
competitors. The emergence of new allegations highlighted a system rooted in social
malpractices and misappropriation of public funds, prompting an urgent reassessment. Viewing
these as a breach of the UN Global Compact, Amundi's ESG rating committee held a special
session in the week following the new revelations.
Key Objectives: Amundi’s key objectives were to reevaluate the issuer based on the new
information, assess their adherence to the UN Global Compact and determine the potential
impact on their ESG score.
Outcomes & Next Steps: In response to the evaluation and the analysis from the ESG analyst
covering the issuer, the committee made the decision to exclude the issuer from Amundi’s
active investment universe. This exclusion reinforces Amundi’s stance against unethical businesspractices and emphasises the importance of ESG considerations in its investment decisions.

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, Amundi’s “Ambition
2025” plan includes a commitment to extend
our ETF ESG products by 2025 to a minimumof 40% of our ETF range. As of December 2022,
27% of the passive fund range is comprised of
ESG funds.

In parallel, for issuers held in non-ESG passive
portfolios but excluded from our active and ESG
ETF universe, Amundi uses our engagement
and voting capabilities to express our concerns.
Where insufficient action is being taken to reduce
harm and/or transition to a sustainable businessmodel, we will vote against the discharge of theboard or management or the re-election of the
Chairman and of some Directors.

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Case study 7: J-Power update for 2022 (Japanese producer of electricity)
Context: In 2021, Amundi, along with other stakeholders, engaged with J-Power under the
AIGCC utilities programme, aiming to enhance the company's alignment with vital climate
and ESG goals. Despite collaborative efforts and improved ESG disclosures by J-Power, itscommitment to Paris Agreement-aligned objectives remains ambiguous in 2022. This ongoing
uncertainty led Amundi, Man Group and HSBC Asset Management to co-file shareholder
proposals at J-Power’s Annual General Meeting seeking to bolster the company’s climate
commitment and transparency. Even with considerable support for these resolutions, J-Power
has yet to demonstrate significant commitment or action. The situation is further complicatedby J-Power's reliance on unproven advanced coal technologies and gaps in their TCFD-aligned
disclosures, particularly regarding physical risk measures and mitigation strategies.
Amundi's Actions: We have actively and rigorously engaged with J-Power, pushing forheightened ESG accountability and comprehensive plans of action. In a dedicated effort toaccelerate J-Power's climate and ESG commitments, Amundi co-filed shareholder proposals
for expedited climate and ESG commitment.
Key Objectives:– Urge complete alignment with the Paris Agreement,– Prioritise established renewable energy technologies and investments, and– Enhance TCFD-aligned corporate disclosure, outlining physical and mitigation risks.
Outcomes & Next Steps: J-Power has initiated adjustments, setting a short-term goal to lower
GHG by seven million tCO2e by 2025 and a 40% reduction by 2030, alongside a JPY 300 billion
investment for renewable projects, aiming for at least 1.5 GW renewable power generation by2025. Despite these steps, their continued reliance on advanced coal technologies and limited
progress in other key areas remain significant concerns.
In the coming period, Amundi will persistently urge J-Power towards a comprehensive andtimely commitment to climate and ESG targets, ensuring alignment with the Paris Agreement.
The focus includes the prioritisation of renewable energy and enhancement of TCFD-aligned
disclosures and strategies. Amid rising support for climate-focused shareholder proposals,
J-Power stands at a crucial juncture for significant strategic adaptations and pledges for
immediate and decisive action.

5. Enhancing integration of ESG considerations into
investment activities: “Say on Climate”
a. Amundi’s “Say on Climate”
Based on the progress of the 2018-2021 ESG
plan, we are especially aware of the efforts thatstill need to be made to ensure that all sectors
and companies adopt a strategy aligned to theParis Agreement.

As shareholders, Amundi strongly encourages
the companies in which we invest to submit
their climate strategy to an advisory vote at theGeneral Meetings.

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As a listed company, Amundi also believes that
we have a responsibility to be transparent with
our shareholders about our climate strategy.
Therefore, in line with the commitment made in

the ESG “Ambition 2025” plan, we submitted our
climate strategy to a consultative shareholder
vote at 2022 General Meeting. The resolution
received 97.7% of votes in favour.

b. Amundi’s approach: a progressive and evolving process
As scientific knowledge and methodologies
grow and evolve, and the broad spectrum ofasset classes and regions of the world in which
Amundi invests do not all yet benefit from theanalytical frameworks and data necessary for acomprehensive action plan, we understand that
Amundi must adopt a progressive approach insetting the ambitions of a long-term climate
strategy, with intermediate steps.
Amundi’s climate strategy will therefore evolve
in-line with methodological developments,
protocols for defining ambitions, regulatory
frameworks and the data available for assessingalignment with a 2050 carbon neutrality
objective.
Based on our commitment to climate issues
and our responsibility to our clients, Amundi’s
climate strategy is dynamic and steady, withshort- and medium-term objectives. It is basedon three convictions:
1. The need for a scientific approach: transition
is a fundamental issue that calls for an industrial
revolution based on both established scientificfindings and the development of proventechnological solutions,2. The need to support the transition ofcompanies in which we invest rather than
excluding them or divesting from them, amethod which must be restricted to businesses

that compromise this transition. The transition
involves supporting the transformation of highcarbon-emitting business models into models
of decarbonised development,
3. The search for social and economic progress:
we are of the opinion that the transition will only
be achieved if it is deemed socially acceptable.
In addition to joining the Net Zero AssetManagers initiative, Amundi has put in place a
Climate 2022–2025 Action Plan based on three
key goals:
1. The integration of climate change within
our business operations, namely the resources
implemented within our organisation, thealignment of our employees, governance andcommitments to reduce direct greenhouse gas
emissions;2. The integration of climate change within
our management for third parties, describing
our commitments in regard to savings andinvestment solutions;3. The integration of climate change within ouractions targeting the businesses in which weare invested, describing our exclusion policy,
shareholder dialogue and policy on the use of
voting rights in order to accelerate the transitionof these businesses to a decarbonised businessmodel associated with the objectives of theParis Agreement.

c. Detail of plan and progress in 2022
The following tables lays out specific objectives defined to meet the three key goals, and theprogress to towards achieving them in the 2022 reporting year.
Target (ifapplicable)

Progress at
31/12/22

Status

4 hours

Ongoing, in linewith objective

94%

Ongoing, in linewith objective

1. Integration of climate issues into the conduct of business
A. Putting climate at the centre of governance
No. of hours devoted by Boardof Directors to climate issues
Role of the Board of
Directors

Average attendance rate at
sessions on climate & responsible
investment

>80%

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Stewardship Report 2022

Employee alignment,
through compensation
policyOctober 2023

CEO compensation plan linked
to ESG & CSR objectives

100%

100%

Achieved

Compensation plan for 200
senior executives linked to ESG &CSR objectives

100%

100%

Achieved

Sales and portfolio managers
assessment & compensation
includes ESG objectives

100%

99%

Achieved*

Reduction in energy-related HGHremission (Scope 1 & 2) per FTE
compared to 2018-30% by2025-51%

Achieved

Reduction in GHG emissions
related to business travel (Scope3) per FTE compared to 201815-30% by2025-75%

Achieved

Integration of the carbon
footprint
Reduction objective into thePurchasing policy

Objective to be defined in
2023

Ongoing, in linewith objective

100%

100%

Achieved

100%

Training
programme
launched in
2022

Ongoing, in linewith objective

3 hours

Achieved

B. Setting objectives for reducing direct emissions

Aligning the CSR policy withNet Zero 2050 challenges

C. Deploying the resources necessary to achieve the objectives
Deployment of resources
dedicated to ESG & climate
commitments

40% increase in Responsible
Investment Team by 2022

100% of employees to undertake
responsible investment training
Ongoing employee training
Number of training hours
dedicated to climate issues
provided to the SLT (Senior
Leadership Team)

Contribution toindustry efforts

Activity report on collective
commitments

Annualactivity
reportCompleted

Achieved

Activity report on Climaterelated
research published by Amundi
on the Amundi Research Centre
websiteAnnualactivity
reportScheduledfor Q1 2023

Ongoing, in linewith objective

3

Ongoing, in linewith objective

2025

Content of
first module
definedOngoing, in linewith objective

Voting policy

AnnualOngoing

Achieved

Responsible investment policy

AnnualOngoing

Achieved

Stewardship Report

AnnualOngoing

Ongoing, in linewith objective

Voting Report

AnnualScheduledfor Q1 2023

Ongoing, in linewith objective

Engagement Report

AnnualScheduledfor Q1 2023

Ongoing, in linewith objective

Climate and Sustainability
ReportAnnualScheduledfor Q1 2023

Ongoing, in linewith objective

Number of Institutional
clients canvassed on Net Zerochallenges
ALTO* Sustainability marketed
and number of modules offered
D. Implement this strategy in a fully transparent manner
Voting & responsible
investment policies

Stewardship Report

Climate Report – TCFD

15. Measurement carried out on entities with more than 100 FTE, in intensity. Excluding refrigerants.

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2. Integrating climate change into management of third parties
A. Systematically incorporating the assessment of transition into actively managed open-ended funds
Incorporating 100% of theassessment of transition into
actively managed openended funds16

Implementing environmental
transition assessment in theinvestment process2025,
preliminary
work started

Ongoing, in linewith objective

6 by 2025

4

Ongoing, in linewith objective

AnnualScheduledfor Q1 2023

Ongoing, in linewith objective

100% by2022

100%

Achieved

100%

B. Developing Net Zero 2050 transition funds on major asset classes
Active management Net
Zero range on the main asset
classesNumber of asset classes offering
Net Zero transition investment
products

C. Contributing to the energy transition financing effort
Supporting the energy
transition financing effort

Activity report on green
solutions, climate

3. Integration of climate issues into business initiative
Divest from unconventionalhydrocarbons

Policy and eligible scope
disinvested

A. Establishing an active dialogue to speed up and further urge the transformation of investee company businessmodelsClimate Commitment
extended to over 1,000
companies

Cycle of engagement with 1,000
additional businesses by 202517+1,000+418

Ongoing, in linewith objective

AnnualScheduledfor Q1 2023

Ongoing, in linewith objective

B. Promoting a socially acceptable energy transition
Activity report on the “Fair
Transition”

Annual report

Amundi will continue to adjust our climate strategy in the coming years, according to the scientificreference scenarios and in close connection with its clients’ objectives, both by investing in solutions
to accelerate the transition and by progressively aligning our portfolios with the 2050 neutrality
objective.

16. Scope of activity managed open-ended funds, where a transitional rating methodology is applicable
17. For information: 547 climate-related commitments from a scope of 464 companies at the end of 2012

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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.
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; and annual supplier assessment
report updated by the ESG Analysis team,
integrating the views of different analysts on
all ESG data suppliers.

76 Stewardship Report 2022

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 to

October 2023

keep up to date with the latest methodologicaldevelopments and to provide feedback on
their services and data, including any potential
shortcomings.

Illustration 16: Carbon data gaps with one of our main provider
In 2022, we observed major gaps in issuers’ carbon data from a year to another. In order tounderstand these gaps we engaged with our data provider to explore them more deeply.
We identified a few reasons for those gaps including: a first year of reporting (vs estimations
before), a change in the estimation model from the provider, the impact of COVID on issuers
absolute emissions.
We put in place more controls and tracking on those gaps following this in order to gain more
comfort on our carbon data.

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.
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. General
meetings of companies’ part of a pre- defined"qualitative universe" (that takes into accountthe financial materiality of the votes at thefund level and aggregated), as well as meetings
considered significant due to the inclusion of
specific proposals (e.g., shareholder proposals
on environmental or social topics) will besystematically reviewed by the team.
Amundi accommodates certain custom voting
policies, provided for specific client mandates.

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Principle 9Signatories engage with issuers to maintain or enhance thevalue of assets
Guided by Amundi's foundational belief in being a trusted, long-term partner working in the interestsof clients and society, our stewardship activities are driven by the ambition to forge a resilient andsustainable economic future. As Europe's leading asset manager, our legacy is deeply anchored in
responsible investment and ESG integration. Our commitment to engagement is deeply rooted inour core investment values, strategies, and ethos (highlighted in Principle 1) and our obligation toserve our clients (as described in Principle 6). Leveraging our expertise, we don't just aim to manage
but to spearhead positive change by actively influencing investee companies. We hold the steadfast
belief that active engagement, when integrated seamlessly into our robust ESG framework, canyield more significant and enduring impacts than mere divestment. At Amundi, engagement is morethan just an activity – it's a pledge, results-driven, and in harmony with our overarching mission tocultivate lasting value for our clients and the wider community.
Amundi's 2022 Engagement Overview: A detailed snapshot of sustainability engagements andtheir geographic distribution, highlighting our commitment to active stewardship.

A year in review
Amundi 2022 Engagement Statistics
2115 unique issuers engaged in 2022 (1364 in 2021, 878 in 2020)*
1200
1104
1031
1000

800
600
344
400

355
315
235

200
0
Transition Towards
a Low Carbon
Economy

E
2021

2022

Natural CapitalPreservation

Social Cohesion

Product, Client,Societal
Responsibility

Strong Governancefor Sustainable
Development

S

Dialogue to Foster aStronger Voting
ExerciseG*Issuers can undergo both AGM related and ESG related engagements

Source: Amundi Statistics 2022
18. These statistics cover both direct engagement performed by Amundi and collaborative engagements where Amundi isactive.

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Geographic Breakdown of Engagement
By number of companies engaged with800

In 2022,76% of Amundi Engagements
were Active Engagements

744

700
600

568

500

476

400

Generic**

471
359

332

300
200

540
488

24%
Active***

76%

249

244
140

154

100
0

Developed Asia Emerging Markets
AGM-related

ESG-related

EuropeNorth America

Total**Generic Engagement: engagement witha specific objective that covers a large
number of issuers***Active Engagement: company-specificengagement

Source: Amundi Statistics 2022

While this principle offers a snapshot of our stewardship efforts concerning engagement, a moredetailed account of all our engagement policies and activities for the reporting period can be foundin our 2022 Engagement Report.

1. The aims of engagement ___________________At Amundi, we define engagement as a process
distinct from corporate access and traditional
corporate dialogue. The primary objective ofengagement is to influence the activities or
behaviors of investee companies, guiding themto improve ESG practices or make an impact on
key sustainability linked topics. More specifically,
this process is characterised by having a specificagenda and targets that focus on real-life
outcomes within a pre-defined timeframe.

Our approach falls into two distinct categories,
which sees us engage issuers to:– Improve their integration of environmental
and social dimensions within their operations
and to strengthen the quality of theirgovernance to limit sustainability risks.
– Elevate their positive impact on key
environmental, social, and human rights
related issues which are material to society
and the global economy and could translate
into higher ESG-related risks, such as
controversies, fines or lower valuation.

a. Selecting Companies for Engagement
Amundi’s engagement process is holistic,
encompassing investees and potential investees,
regardless of the nature of our holdings. The
selection hinges on an issuer's exposure to
the specific engagement theme, termed the'engagement trigger'.

Given the potential far-reaching implications ofenvironmental, social, and governance issues oncompanies, it is imperative to evaluate an issuer's
ESG calibre, irrespective of the size of our stake.
ESG challenges with financial repercussions areintegrated by our investment experts into theirvaluation models and investment protocols.

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Our engagement, therefore, addresses ESG
issues at the issuer level. Amundi's investment
professionals not only delve into ESG topics
pivotal for the valuation of the instruments they
invest in, but they also engage in holistic ESGfocused dialogues with issuers.

Recognising the diversity across regions, ourengagement strategy, while maintaining a global
ambition, adapts to regional nuances to reflect
the reality of the situation on the ground in the
different geographies we invest in. The intent
is to foster a globally consistent yet locally
relevant impact, contributing significantly to theglobal financial community's collective efforts.

a. How We Engage
Amundiconducts
engagements
bothindividually and collectively with other investors.
Collaborative Engagement: Working with Our
Peers to Help Drive the Conversation
Collective efforts can often have 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 collaborative engagement or
our own, Amundi will choose the most efficientmethod to push the agenda, which may favour
a collaborative method. We might supplement
collaborative efforts with direct engagement
if a collaborative engagement does not coverparticular issues, sectors, or companies, or if
the collaborative initiative does not address the
topic in a way Amundi might wish. Amundi values

both engagement types as a means to have apositive impact on sustainable outcomes, andwill only be active in a collaborative engagement
when it is in line with our own policy.
Further details of our collaborative efforts canbe found in Principle 10.
Direct Engagement with Issuers
Where Amundi chooses to engage on astandalone basis with issuers, we do so throughvarious means of communication. This can
include in-person meetings, phone or video
calls, emails, formal letters or questionnaires.
We divide these forms of communication into
two categories: active engagement and genericengagement. Whatever the format, the ultimate
aim is to set an engagement objective and to
track and monitor a company’s progress.

How we Engage: defining Active Engagement
Selecting an Active or Generic Engagement Strategy

Generic Engagement
Specific objectives, aimed
to target a large number ofcompanies

Active Engagement
Robust, in depth, company
specific dialogue

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Active Engagement with Issuers
Active engagement is defined as any
engagement which includes active dialogue
between Amundi and the company. For active
engagement, the targets or intermediateobjectives of active engagements are specificto the situation of each issuer. This can include
robust dialogue on topics through meetings,
calls, direct emails, and questionnaires. With
active engagement, company replies are often
robust and they provide us with extensive
information to set engagement objectives andtrack progress.
Generic Engagement
Generic engagement is how we describe
engagement campaigns that cover large

October 2023

numbers of companies and very specific (often
more narrow) engagement objectives. These
campaigns are usually done via email and enable
us to reach a larger numbers of companies
simultaneously
where
the
engagement
objective is, for the most part, uniform acrossthe entire engagement group. One example
is how we communicate our thermal coal
policy to companies and outline our objectives
accordingly. Large engagement campaigns arearguably limited in scope but they have theirown value as they enable us to target a larger
number of issuers with specific requests related
to Amundi policies and ambitions.
Generic engagement could also be the first stepof an active engagement in order to set clear
expectations to a large number of companies.

B. Addressing Regional Nuances Through Collaboration of Portfolio
Managers and Analysts
Amundi is a global organisation; not only interms of where our clients are based and thetypes of assets we manage on their behalf, butalso in terms of having a presence in different
regions. We are headquartered in France, which
is where 50% of our employees are located,with nearly a third of our remaining headcountbased across the rest of Europe, 10% in theAmericas and 8% in Asia. This gives Amundi onthe-ground intelligence about the local nuancesof these markets, whether regulatory, politicalor socio-economic, and allows us to adapt ourengagement approach based on the reality ofthe situation on the ground.
One example of how these insights support
Amundi's stewardship activities is the way inwhich the ESG Research, Engagement, andVoting team has developed a robust set ofresources to support investment professionals
in their engagement processes, which take into
account regional nuances. This informs theme
selection, issuer targeting, best practice in how
to conduct thorough engagements with explicit
and actionable demands, and monitoring
progress. While ESG considerations are integral
to our company-wide dialogues, it's evident
that our ESG analysts, in collaboration withinvestment professionals, are pivotal to achieving
Amundi's engagement goals. Apart from theirin-depth ESG interactions, these professionals
also address ESG topics of financial significance.
Our global team of portfolio managers and both
ESG and financial analysts engage in meaningful
discussions, ensuring that local insights areincorporated. The overarching aim is to maintainglobal standards while accommodating regional
specificities.

C. Measuring, Monitoring, and Escalating in the Engagement Process
Defining the Engagement Period
Amundi's engagements typically span aroundthree years, varying based on the defined
agenda. Progress and developments are
systematically tracked through our internal
engagement tool, accessible to all investment

platforms. Through yearly assessments, we aim
to maintain an ambitious yet practical dialogue
with investees, fostering broad-spectrum
actions for the collective benefit. At the heartof our mission lies the belief that constructive
dialogue is foundational to advancing towards asustainable, low-carbon economy.

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Measuring Engagement Progress
Amundi diligently measures issuers’ progress
toward set objectives using defined milestones.
Our paramount goal is to effect positive impact,
so we shape our engagement strategies aroundefficacy. Navigating transformative changes
in large organisations can pose considerable
challenges for issuers. Adopting a long-term
perspective, we frame intermediary targets
for engagements, considering the unique
circumstances of each company. Balancing
our aspirational long-term objectives, weemphasise achievable and quantifiable short
to medium-term enhancements. As proactive
investors, our role is to be both rigorous andadaptive, championing the shift to a sustainable
and inclusive economy. Recognising existing
challenges in accurately gauging sustainability,
climate, and human rights themes, we viewsustainability as an evolving benchmark.
Consequently, our engagement approaches arecontinually refined to resonate with emerging
insights.
Amundi’s Dedicated Proprietary
Monitoring Engagement

Tool

for

All open engagements are recorded and areaccessible to all investment professionals. For
transparency and traceability reasons, any fundmanager or financial analyst can contribute. In
order to monitor issuer-specific engagement
objectives and the ensuing progress, Amundi
has created a proprietary engagement reporting
tool. This tool documents the feedback provided
to issuers on specific engagement topics (interms of KPIs for performance improvements)
and tracks issuer performance towards thesetargets. An internal milestone system assesses
progress towards these KPIs including:– Issuers who have made little or no progress
towards the target after a sufficient periodof time or have remained unresponsive,(negative) flagging them for a potential
escalation depending on the severity of theissue,– Issuers who have not yet indicated if andwhen they will achieve the objective, but it isstill too early to assess if their trajectory is apositive or negative, or issuers that have hadvaried progress (neutral), and– Companies who have largely met the KPI or
are on course to achieving the KPI in the near
future (positive).
Engagements logged in our tool can generate
auditable statistics to assist in reporting.
Engagement Escalation
When engagement fails or if the action /remediation plan of the issuer appears weak,Amundi employs a "Toolbox" approach toengagement escalation, aiming to incentivise
positive change in issuers. We may enact amode of escalation up to exclusion from active
investment universe, meaning all active investing
strategies over which Amundi has full discretion.
Escalation modes include (in no particularorder), negative overrides in one or several
criteria of the ESG score, questions at AGMs,
votes against management, public statements,
ESG score caps and ultimately exclusion if thematter is critical.
See additional detail on how we escalate ourstewardship activities to influence issuers in
Principle 11.

2. The Nature of Engagement _________________Engagement centres on various sustainability
aspects, can involve multiple approaches,
expect different outcomes, and be initiatedbased on unique rationale.

Amundi aims to reach a balance between
ambition and pragmatism in order to optimise
the efficiency of our engagement and therefore
maximise our impact. For this reason, whilepursuing the same midterm goal, our practices
and demands are adapted to the context of ageography, market, theme or issuer.

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A. Themes Framing our Engagement Activity
In 2022, we continued to engage with issuers
within our six key themes:
1. Transition towards a low carbon economy,
2. Natural capital preservation (ecosystem
protection and fight against biodiversity loss),
3. Social cohesion through the protection of
direct and indirect employees, promotion ofhuman rights,
4. Client, product and societal responsibilities,
5. Strong governance practices that strengthen
sustainable development, and
6. Dialogue to foster a stronger voting exercise
and a sounder corporate governance.
Promoting the UN Sustainable Development
Goals through Engagement
In 2015, the United Nations Member States
adopted the 2030 Agenda for Sustainable
Development, which aims to provide a “shared
blueprint for peace and prosperity for people andthe planet, now and in the future.”19 Sustainable

Development Goals (SDGs) are a globally
collaborative and relatively comprehensive
set of goals that apply to all countries and allactors. They include universally pressing issues
such as poverty reduction, health, inequalities,
environmental
sustainability,
ethics,andeconomic 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 thebroader society and private entities to engage
in sustainable development in a meaningful way.
The SDGs do not always directly correlate to
ESG but they can provide a framework for where
investors can help promote global sustainable
development through a wide variety of products
and strategies within the realm of responsible
investing.

Incorporating the SDGs into our Amundi ESG & Engagement Process
17

PARTNERSHIPSFOR THE GOALS

16

PEACE, JUSTICEAND STRONG
INSTITUTIONSESG Rating

01

NO POVERTY

0215• Measures company
performance• Sector based

ZERO HUNGER

LIFE ON LAND

14

SDGs
• Measures Global impact• Issue/theme based

03

LIFE BELLOWWATERGOOD HEALTH& WELL-BEING

Strong overlap
between Amundi
ESG methodology
and SDGs

13

CLIMATE ACTION12RESPONSIBLE
CONSUMPTION AND
PRODUCTION

04

QUALITYEDUCATION

05

GENDEREQUALITY

0611

CLEAN WATER
AND SANITATIONSUSTAINABLE CITIESAND COMMUNITIES07

AFFORDABLE

10REDUCEDINEQUALITIESAND CLEAN ENERGY

09

INDUSTRY,INNOVATION AND
INFRASTRUCTURE

08

DECENT WORKAND ECONOMIC
CROWTH

1. Identify the overlap between
SDG Targets and Amundi ESG
rating Criteria

2. Create a Bridge between
UN SDG Indicator and Amundi
Engagement KPIs

Identify the most material SDG targets andindicators for each sector which SDGs arereflected in our rating criteria

Reinterpret nationality focused KPIs into
corporate engagement KPIs to encouragecompanies to concretely contribute to the SDGs

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

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Engagement remains a key tool to promote the SDGs by influencing investees to tackle thosechallenges and have a positive impact on their outcome. While not all SDG indicators may be relevantto the target sector, the SDGs can help drive the engagement agenda to SDG goals and targets
where the private sector has a key role to play and where investor engagement can encourage
greater momentum.

ESG themes

Primary SDGs

Transition towards a low
carbon economy

Natural capitalpreservation

Social Cohesion

Client, Product &Societal Responsibility

Governance Practices
for Sustainable
Development

Dialogue to Foster aStronger Voting Exercise

B. Factors Triggering our Engagement
Amundi initiates engagement based on
specific context, issuer-related situations, orsustainability concerns within a company.
Companies might also be approached based on
how material or salient a particular theme is to
its business model or their exposure to relevantrisks/opportunities.
While the general areas of focus remain
consistent, the specific reason for engaging
with each company varies. Our overarching goal

is to either enhance their practices or suggest
phasing out certain activities.
At times, the engagement aims to highlightsustainable
opportunities
that
could
deliver additional benefits to companies
and stakeholders. Regardless of the topic,
Amundi wants to encourage overall improved
performance as well as encourage companies
to meet specific performance benchmarks or
impacts.

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There are various triggers which prompt contextual engagement. They include:

Pre AGM

Specificchallenges,
Risks,
opportunities

Specific
Asset
ClassesContextual
Engagement

Company
ESG
performanceControversies

Amundi
Specific
Policies

1. Pre-AGM Dialogue: Amundi may engage in pre-AGM dialogue to encourage sounder corporate
governance that is in line with our Voting Policy. These discussions, beyond addressing AGM agenda
items, provide opportunities to directly engage board members on key sustainability issues. We
encourage board accountability in terms of social responsibility and climate strategy. For underlying
ESG issues, our ESG Research and Voting & Corporate Governance team may conduct joint company
dialogues. Our voting patterns mirror our overall approach to stewardship, meaning that we arecommitted to long-term relationships with the companies in which we invest, and strive to haveactive dialogue with them. Amundi is committed to transparency and, where possible, we inform
issuers of planned negative votes.

Case study 8: Pre-AGM Engagement
Company: Intel Corporation
Context: Since 2021 Amundi has been asking companies to include ESG criteria in their variable
remuneration. The Voting team has subsequently been reinforcing its expectations regarding
the quality of the criteria used and the disclosure provided. Amundi excepts all criteria used inincentive schemes to be clearly defined and linked to strategic targets. We therefore engaged
with some of our portfolio companies that did not meet this requirement.
Amundi Actions: Amundi engaged with Intel Corporation to discuss, most notably, the lackof transparency on the performance goals used in its CEO remuneration. We highlighted theimportance of the integration of ESG metrics in executive compensation, aligned with thecompany’s strategy and with rigorous and quantitative targets.
We informed Intel Corp. of our position, including our policy to vote against the compensationof companies that do not meet this requirement.

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Engagement outcomes and issuer momentum:
In 2022, Intel provided enhanced disclosure regarding the ESG metrics and achievement
against the related goals outlined in its 2021 Annual Cash Bonus Plan:– Environmental Sustainability: Goals related to energy conservation and net positive wateruse.
– Diversity & Inclusion: Goals related to global inclusive hiring practices in support of our2030 RISE workforce inclusion goals for gender and URM diversity.
Next steps: Amundi acknowledged the improvement made by Intel regarding the transparencyof E&S criteria and targets but still voted against because of other issues in the remunerationplans. The Voting team informed the company of the remaining concerns.

2. Engagement around Specific Challenges,
Sustainability Risks, or Opportunities:
Contextual engagement can be triggered by
specific challenges or sustainability risks facedby the issuer or its sector. An example includes
industries utilising a specific metal whose
extraction might imply human-right related
challenges. Examples of how we exercise ourrights and responsibilities can be found in
Principle 12.

4.Amundi specific policies:
As part of its fiduciary responsibility, Amundi
has set minimum standards and exclusion
policies on critical sustainability topics. Specificmonitoring and escalation procedures are
triggered when breaches are identified, which
can lead to engagement, specific voting actions(when applicable) or exclusion. Details on ourstewardship escalation activities, which includes
exclusion, can be found in Principle 11.

3. Specific ESG Performance:
A company’s ESG performance, whether ingeneral or based on our proprietary ESG Rating
Tools, can trigger engagement. For those lagging
or showing progress, the engagement aims
at spurring improvement in ESG performanceor endorsing the adoption of industry bestpractice. Engaging with a company may require
multiple angles and thus the above are notmutually exclusive. For illustration, please see
the updated ENN case study on page 89 of thisreport5.Engagement following a controversy:
Please refer to the case study on the emerging
controversy in a European nursing home chain,
as detailed in Principle 11, for additional details.

C. Established
Expectations

versus

6. Engagement for specific asset classes:
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.
An example of our engagement with sovereignissuers, in this case Hungary, can be found laterin this principle.

Emerging

Established Themes
Amundi recognises that our demands andexpectations of issuers depend on their level ofmaturity; the particular circumstances they face,such as the country in which they operate; aswell as the nature of the theme in question. For
established themes that are frequently discussed

Themes

Shaping

Outcomeand well researched, such as climate and water
risks, yet still require enhanced corporate
practices, Amundi’s objective is to push for the
adoption of best practice. While improvementon these themes is still expected, companies
and sectors are likely to have a strong level ofawareness of the importance of the topic.

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Emerging Themes
Emerging themes are important for thetransition towards a sustainable, low carbon
and inclusive economy, but awareness remains

limited and best practice is still emerging. With
these themes, Amundi’s objective is to raiseawareness, create positive momentum andcontribute to establishing market standards.

D. A Specific Relationship with Investees Leading to Specific Target
Setting and Modalities
Engagement
offersinvestees
Amundi’sperspective on industry best practice and canprovide important insights for corporates,
especially on emerging topics. This is significant
as it encourages them to see the benefit ofengagement, rather than dismissing it as auseless exercise.
Amundi engages current or potential investee
companies at the issuer level regardless of thetype of holdings held. The primary criterion for
selecting issuers for engagement is their level of
exposure to the engagement topic.

Given the sustainability implications ofenvironmental, social, and governance issues,
both in terms of risk and opportunities, weneed to assess the ESG quality of an issuer
regardless of our position in the balance sheet(whether a shareholder or a bondholder). If ESG
issues could have financial consequences forbusinesses, those issues will be considered by
our investment professionals (equity or credit
analysts, portfolio managers) in their valuation
models and investment processes.

Illustration 17: Engaging with all companies, no matter their ESG performance, is
important to trigger adoption and improvement of best practices
Engagement angle for
ESG performance

Definition

How and why Amundi engages
on this angle

Engagement with Leaders

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

Engaging with leaders can help Amundi
get a better sense of current bestpractice and the direction the sector isgoing in 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 practice suchas SMEs (small-medium enterprises) orcompanies in emerging markets.
Engagement with Laggards

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

Engagements target specific areas
where companies lag behind and aim toincentivise 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

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E. Asset-class Based Engagement
Private Equity
We exercise our responsibility as an investor
through shareholder dialogue with companies,and consider ESG factors in our investments
and our voting policy.
Amundi Private Equity Funds follow the Amundi
Asset Management voting policy in theircompany interactions, with particular focus on
two societal issues:– The energy transition, in particular the
decarbonisation of the economy.
– Social cohesion, particularly employee
welfare and profit-sharing systems in privatecompanies.
CSR functions became more deeply embedded
within senior management during 2022 andwere elevated to the highest level of governance.
Indeed, about 70% of companies in our portfolios
review ESG matters either at the Supervisory
Board level (or equivalent) or at the Executive
Committee level - sometimes at both levels.
Once we invest in a Private Company, we
have a seat on the Supervisory Board and arecommitted to accompanying them on theirsustainability journey. To this end, we define
an ESG roadmap with each of our investee
companies. One of the first commitments we
ask is to link the variable remuneration of theCEO, as a minimum, or of the whole Executive
Committee to ESG metrics. While this wasdifficult to achieve in 2022 (only one company
complied), we anticipate a shift in attitudes andbetter rates of acceptance in 2023. In order tobe aligned with our two specific focus issues,
we systematically promote:– one climate KPI: carbon assessment, carbon
reduction roadmap, SBTi certification, etc.;– one social KPI: gender diversity, better
profit-sharing system, opening the capital toemployees, etc.

In 2022, we also frequently engaged withcompanies on ESG reporting, as 75% of ourportfolio will be submitted to the Corporate
Sustainability Reporting Directive and for many
this will be the first time they will have to do thisreporting exercise. Consequently, we talked a
lot about how to complete a materiality matrix,
about double materiality and how to organise
and identify the right metrics. Some companies
are still in the denial phase while some others arepreparing for this new ESG reporting and see
it as an opportunity to improve their businessmodel in a changing world, even though they all
fear the hard work that needs to be done to becompliant by 2026.
Another topic we fight for is to get a better
gender diversity at investee companies. Only
16% of our investee companies are genderbalanced and most of them are male dominated.
This can be explained in part by the sectors inwhich the companies sit (many are in the STEM
sector), but at Amundi we think that diversity
is a source of performance. Despite this, weare happy to see that all companies are above
the 75% minimum level required by the State
Equality Index and that 36% of them have evenobtained above 85%.
More information on our approach to gender
diversity can be found in Principle 1.

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Case study 9: tech company
Context: In 2022, we invested in a tech company who presents itself as a digital transformation
operator. As with many private companies in France, their CSR framework lacked structure andmanagement experience in this area.
Amundi Actions: Quite rapidly, Amundi decided to engage with the company in order todiscuss ESG and to improve the company’s understanding and approach to the topic. We
offered to lead on the ESG Roadmap on behalf of other investors. We managed to agree 22
ESG actions to implement, including:– ESG KPIs in the variable remuneration of the Executive Board;– Carbon assessment (Scopes 1, 2 & 3);– Improving the State Equality Index up to 85%;
– Completing a materiality matrix in order to be prepared for the CSRD;– Having at least one women at the Executive Committee;– Implementing a Responsible Digital policy;– Widening the number of employees who can be shareholders;– Implementing a Diversity & Inclusion Policy;– Engagement outcomes and issuer momentum
At the end of 2022. We were happy to see that a carbon assessment is planned for the firstsemester of 2023, a woman will be promoted to the Executive Committee and the company isvery near to reaching the 85% for the Gender Equality Index.
Next steps: We will continue to closely follow the engagement and follow up with the company
on specific ESG matters and targets that are yet to be set or achieved, to help the company
meet its ESG targets over time.

Fixed Income
When it comes to corporate and sovereign debt stewardship, Amundi’s approach centres aroundteams of specialists that provide a variety of assessments; including proprietary, fundamental
analysis and covenants, prospectuses and transaction document assessment when needed. In caseof default, Amundi actively participates in negotiations with the issuer and the other investors. When
we are a member of the restructuring steering committee, Amundi seeks to protect the interestsof our own clients, but also those of the other investors, rather than members of the committee.
We also push, when possible and relevant, to include sustainability related KPIs, however this is notalways possible as terms are approved by all investors, and the distressed issuer might not have theresources nor the processes to comply with such a demand in the short term.

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Case study 10: Amundi's Active Role in a Kazakhstan Company's TurnaroundContext: In 2020, a Kazakhstan-based company defaulted, triggering a restructuring process.
Amundi was involved from the start and participated in negotiations with the issuer and its
debtors.
Amundi Actions: The company was significantly restructured in the following years, with its
governance overhauled, and it is now following the UK Corporate Governance Code. Amundi
has participated in the selection of the new board members and the chairman.
Engagement outcomes and issuer momentum: Debt investors and the issuers reached anagreement on the restructuring of the debt in late 2022. After the application of an haircut,
the debtors will become shareholders of the company, following the general assembly that will
occur at the beginning of 2023.
Next steps: Amundi is continuing to closely monitor this issuer and is engaging with thecompany in order to foster a stronger incorporation of sustainability, such as climate related
KPIs, in compensation packages and gender diversity at board level.

Case study 11: Sri Lanka's Debt Crisis - Amundi's Pursuit of Socially Conscious
Restructuring
Context: In April 2022, Sri Lanka declared the country was suspending payment on mostforeign debt for the first time in its history.
Amundi Actions: Amundi actively participated in the restructuring discussions that took place
between debtors and the country, as part of the steering committee. During the process,Amundi pushed to include social elements into the restructuring.
Engagement outcomes and issuer momentum: The country did not have the resources orprocesses in place to be able to issue a socially linked bond at that time.
Next steps: Amundi continues to advocate for the inclusion of social KPIs in sovereign debts,
but recognises that it could be challenging for them to meet the level of disclosure requiredby investors.

Supporting Emerging Markets for ESG Integration
and Disclosure
It is the conviction of Amundi’s Emerging Markets (EM) team that engagement can drive value in amutually beneficial way. Apart from the different engagement streams that could trigger dialogues
with issuers in emerging markets; our ESG Research team, EM fund managers and financial analysts
have worked together to build a specific engagement stream for emerging markets.

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➜ Our progress in 2022
In 2022, continuing from our initiatives in the previous years, the specific Emerging Markets
Engagement campaign on ESG issues further expanded its scope. Out of the 568 emerging
market-related engagements conducted globally, our EM portfolio managers and financial
analysts had conversations with 113 companies. This marks an increase from 107 in 2021 and 80
in 2020, spanning regions such as Central and Eastern Europe, the Middle East, Africa, Latin
America, and Emerging Asia. Maintaining our approach, most of these engagements remained
bottom-up, zeroing in on company-specific material issues through Amundi's proprietary ESG
rating tool. The selection of issuers was primarily based on their potential as ESG improvers, as
indicated in the updated ENN case study below. In 2022, given its overarching significance, thetopic of net zero was integrated into most of our questionnaires. We also ventured into diverse
themes such as gender diversity, human rights and biodiversity, among others.

Outcomes:Throughout 2022, our continued engagements resulted in sustained interest from emerging market
issuers. They were keen to better understand ESG materiality and the weight it holds for investors,
both as potential risks and opportunities. ESG standards in emerging markets are gradually aligningwith those in developed markets. Despite the evident progress, there remains a long road ahead.
We are optimistic about the substantial value that can be unlocked through these engagements.
Given the anticipated growth trajectory for EMs in the coming years, it will be even more vitalfor businesses within these regions to evolve responsibly. This growth should focus on minimising
adverse impacts while optimising value generation for both shareholders and stakeholders.

Case study 12: 2022 Update of Ongoing Engagement with ENN Energy on
Strengthening ESG Practices
Context: Amundi began its engagement with ENN Energy Holdings, a gas utility based in China
in 2021, focusing on certain E, S, and G criteria that seemed to be lagging. These concerns
included GHG emissions, health & safety, and specific corporate governance practices. This
engagement was initiated to better understand the company's plans and actions towards
improving these criteria.
Amundi Actions: Throughout 2021, Amundi held multiple discussions with ENN Energy
addressing these topics. The primary objective was to comprehend the company's direction
and anticipate potential changes. ENN Energy exhibited promising ESG momentum. To further
this momentum, Amundi provided several recommendations:– Committing to phasing out thermal coal by 2040, aligning with Amundi’s coal policy,– Setting clear GHG emissions targets, especially expanding targets falling under Scope 3,– Adopting and disclosing climate-related risks and opportunities according to the TCFD
framework,– Enhancing health & safety measures by expanding H&S certifications to more member
companies, and– Promptly implementing ethics training for all suppliers and contractors.
In 2022, we continued our engagement with ENN Energy, tracking their recent progress andadvising on further ESG enhancements.

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Stewardship Report 2022

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Engagement Outcomes for 2022:
ENN Energy demonstrated significant progress in 2022:– Scope 3 Emissions: They initiated a Scope 3 emissions accounting programme througha third-party consulting agency, transitioning from a Scope 1&2-focused plan to acomprehensive carbon management approach,– TCFD Alignment: Severe flooding in Henan Province in July 2021 acted as a catalyst.
Consequently, a quantification pilot for climate risk in line with the TCFD framework wasundertaken. This pilot is intended to guide ENN Energy’s future TCFD-compliant reporting,aiming for company-wide adoption.
– Health & safety: By the end of 2022, ISO 45001 H&S certification was expanded to 62
member companies, which account for over 70% of the company’s revenue. ENN has set
an ambitious goal to certify companies contributing to more than 80% of its revenue by
the end of 2023. While Amundi continues to advocate for 100% site certification, ENN has
expressed challenges, especially with smaller member companies.
– Business Ethics: The company now mandates all its suppliers and contractors undergobusiness ethics training. This is achieved through the Bidders' Commitment to Integrity and
Self-Discipline and additional training modules.
– Coal Phase-Out: ENN Energy is committed to phasing out coal by 2040 in line with
Amundi’s policy. They are also exploring certification possibilities with the Science Based
Targets initiative.
Next Steps: Amundi acknowledges ENN Energy's commendable ESG progress and remains
committed to supporting their journey. Feedback for future improvement includes:– A publicly communicated, definite plan for phasing out thermal coal,– Concrete targets and strategy for Scope 3, absolute emissions reduction targets for Scope 1
and 2,– Aiming for 100% company site certification to international H&S standards, such as ISO
45001,– Seeking certification from the SBTi,– Conducting business model stress testing using the IEA NZ Scenario carbon price, and– Expanding assessment of climate-related risks and opportunities in alignment with the
TCFD framework.
Amundi believes some of these actions are already on ENN Energy's roadmap and offers its
continued encouragement and support for their full realisation.

Engaging with sovereign entities
Engagement with sovereign issuers is gaining momentum in the market but is generally lessdeveloped than engagement with companies. According to the PRI, the four main barriers toengagement with sovereigns are:1. the fear that voicing concerns could be interpreted as political criticism;2. the lack of impact if holdings are too small and the risk of attracting undesired attention if holdings
are large;
3. the rise of passive investment, which provides structural demand for sovereign issuers included
in major bond indices;
4. the perception that ESG risks are relevant mainly for emerging markets.

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Amundi's Approach to Sovereign Engagement:
Amundi's sovereign engagement is built on multiple pillars, integrating the ESG research andengagement teams (Sovereign ESG and GSS bond analyst teams) with portfolio managers.

Amundi Asset Management's Sovereign Framework
Issuer Level

Sovereign ESG Team / EMD PM team participate ininvestor calls with the Ministry of Finance etc.

Bond Structuring / Restructuring

PM use bondholder position to pin relevant KPIs to thebond structure (exemple, via SLBs)

Industry Level Collaboration

Amundi is part of the Advisory Group of UN PRI led
ASCOR project, sharing expertise & skills to help develop
a Sovereign ESG framework (participants include pension
funds, TPI and asset managers)

Source: Amundi Asset Management

Case study 13: Sovereign Engagement – Hungary
In October 2022, Amundi engaged with officials from Hungary’s Ministry of Finance, Debt
Management Agency and Ministry of Energy to review and discuss the country’s Green Bondframework and its transition towards a low carbon economy. Amundi raised two main issues:– The EU Taxonomy alignment of the framework was not yet fully assessed;– The transportation sector is lagging behind the country’s 2030 emissions reduction target.
The issuer acknowledged the issue of the taxonomy alignment and said to be working on it.
The country has also announced plans to implement additional policies that should accelerate
the energy transition.

Case study 14: Update to 2021 engagement with Latin American sub-sovereignissuer
In 2021, Amundi was one of the 10 bondholders involved in discussions for the restructuringof a Latin American sub-sovereign issuer. Amundi proposed the restructured bond coupon belinked to SDG 4 (quality education) or SDG 6 (clean water and sanitation) via a Sustainabilitylinked bond format.
2022 Update:Amundi’s proposal was not included in the restructuring (mostly due to political issues andtime pressure). It has nonetheless expressed keen interest to issue a SDG-linked bond in the
future.
In 2022, Amundi has intensified its collaboration with sovereign issuers, particularly throughcombined thematic engagements, such as their initiatives on thermal coal alongside utility
firms and banks (refer to the Indonesia case study on pg. 68 in Principle 7).

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Supporting Green bonds to make the energy transition
concrete.
Amundi sees the green bonds asset class as
pivotal in directing private capital to address
the financial demands of the energy transition.

Our primary engagement around this asset
class continues to focus on the improvement ofreporting capabilities.

Context: Green Bonds Engagement Overview
Amundi launched a thematic engagement
campaign centred on green bonds in 2021.
The objective was to spur greater compliancewith ICMA’s Harmonised Framework for Impact
Reporting and Life Cycle Assessment (LCA). As
a green bond investor, the assessment of thegreen bond and the impact from green projects
does not terminate upon completion of theissuance, but continues throughout the durationof the green bond while it is outstanding via what
is called impact reporting. For good governanceand integrity of the green bond market, we

believe that green bond issuers should ensure
continuous efforts are made to improve theconsistency and availability of reported metrics
over time. Through engagement, almost allissuers have shared the difficulties of collecting,harmonising and reporting on the relevant
climate impacts and metrics when projects
cover a wide variety of categories.
In 2011 we have continued the campaign with thesame green bond issuers to track their progress
and the challenges they face.

Engagement Selection:
We have engaged with a total of 20 issuers,
with an equal split between developing anddeveloped markets, from six different sectors:

automobile, bank, real estate, transportation,utilities, and renewables.

Engagement Objectives:
There were two broad aims for our engagementsthat apply to all sectors:
1. Encourage alignment with the ICMA
Harmonised Framework for Impact Reporting

2. Encourage adoption of the LCA approach ingreen bond impact reporting➜ Our progress in 2022
Engagement Outcomes & Issuer Momentum:
Since the commencement of the initiative in 2021, six of the 20 participants responded positively
in 2022, taking actions based on our feedback. These companies exhibited behaviors such as:– Having undertaken Framework implementation steps, with plans to publish new impact
reports in the forthcoming year or upon the next green bond issuance,– Shifted from reporting "until proceeds have been fully allocated" to ongoing reporting as
long as a green bond remains outstanding, and– Enhanced sustainability data reporting, emphasising Scope 3. However, green bond reports
might not yet incorporate a crucial aspect of LCA, capturing Scope 3 emissions across thevalue chain.

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Out of the six issuers with positive traction, it is quite balanced in terms of issuers fromdeveloped and developing markets.
2022 Outcomes for Harmonized Framework for Impact Reporting
We have seen noticeable progress around the adoption of the Harmonised Framework, which
we believe has to do with greater awareness and more efficient collection of the non-financial
data and drivers that make impact data on project level readily available. One of the main
drivers is the implementation of the ECB’s Guide on climate-related and environmental risks,
which has refined quantitative assessment techniques for climate-related aspects. While wehave observed commitments for future compliance, our focus remains on monitoring its actual
execution.
Regarding the Harmonised Framework for Impact Reporting, we witnessed meaningfulprogress and commitments in 2022.

Internal scoring assessment on LCA

Harmonized framework for impact reporting
3
2,5

2,7

2,7
2,3

2,5
2,0 2,0

2

1,9

2,0

2,1

1,8
1,4 1,51,51,0 1,010,50Automobile

Banks

Average Score in 2021

Real Estate

Renewable Transportation Utilities

Grand Total

Average Score in 2022

Source: Amundi Asset Management

2022 Outcomes for the LCA Assessment
Regarding the LCA assessment, its advancement in green bond reporting has been limited. Most
progress centres on broader business operations and sustainability, not green bond specifics,
possibly due to challenges with Scope 3 emissions data. While some strides are being madein supplier data, the adoption of LCA in green bonds differs greatly. For instance, while manyin the manufacturing sector have thorough, sometimes third-party verified methodologies,
issuers from less manufacturing-focused industries show little to no progress.

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Chart: LCA for impact reporting with minimal progress seen over the past year

Internal scoring assessment on LCA

LCA for impact reporting3

2,7 2,72,52
1,51,0 1,0

1

1,7 1,71,5 1,5

1,4 1,4
1,0 1,01,0 1,00,50Automobile

Banks

Average Score in 2021

Real Estate

Renewable Transportation Utilities

Grand Total

Average Score in 2022

Source: Amundi Asset Management

A good example of best LCA best practice is an automobile manufacturer, Volkswagen, whichis reporting in full alignment of the Framework related to green bond impact data and report,
LCA assessment with clear explanation and methodology with independent verification.

Case study 15: Volkswagen Group – A Model for Green Bond Reporting
Context: Volkswagen Group (the “Group”, or “VW”) is one of the leading automobile
manufacturers and the largest carmaker in Europe. In 2018, Volkswagen Group was the first
automaker to commit to the Paris Agreement, aiming to be net carbon neutral by 2050 thelatest. For VW, the goal is to embrace the sustainability transformation in the transport sector,
and become a leading provider of sustainable mobility. To align with the Group’s overallsustainability strategy, the first Green Finance Framework (the “Framework”) was launchedin March 2020. This was followed by its inaugural EUR 2 billion of green bond issuance in
September 2020.
VW’s emission scandal and controversies in the past have prompted the issuer to put in efforts
to ensure its green bond issuances are not only meeting minimum requirements, but also follow
investor expectations and adopt some of the best practices. Specifically for green bonds, webegan our engagement with VW since 2021 following the release of its first allocation andimpact report on two main themes a) alignment with Harmonized Framework for Impact
Reporting and b) life cycle assessment (LCA). And in 2022, our engagement continued andfurther expanded to include other market developments in the green bond market such as EU
Taxonomy alignment at the green bond level.
Amundi Actions: Amundi has encouraged VW to adopt market practices including disclosureof EU Taxonomy alignment beyond company, and onto green bond level of alignment, withclear disclosure of assessment in details to address technical screening criteria, do no significant
harm and minimum safeguards.

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Key Objectives for our engagement were as follows:
Promote best practices and improve transparency on the level of details on green bondprojects and methodology:– The automotive industry’s share of green bond issuance has increased over the past few
years and expected to grow further as the industry steps up its decarbonization efforts,
along with greater regulatory pushes for electric vehicles (EVs) where many places arephasing out vehicles with petrol-consuming internal combustion engines and targeted
investments in EVs in its related infrastructure and ecosystems. VW was among the top
issuers of green bonds, in terms of issuance volume, from the automotive industry in
2022, and our objective of the engagement with VW is to ensure frequent and large green
bond issuers such as VW are aware of investor expectation and adopting best market
practices such as disclosure of EU taxonomy alignment, and strong preference of capital
expenditures over operating expenses for use of proceeds.
– As we began our green bond allocation and impact including life cycle assessment (LCA)
in 2021, car manufacturing is a critical sector because LCA has been used in the automotive
industry for more than 20 years, mainly help to identify environmental hotspots and areasof innovation. Hence, they are also early adopters of LCA assessment and impact analysis
for green bonds. Key objective of our engagement is also to understand and share withissuers from other sectors automotive industry’s experience and work related to LCAs.
Engagement Outcomes and Issuer Momentum
In 2022, we observed key outcomes including:– VW has taken into the feedback on market practices and updated its green financeframework to incorporate the latest development on EU taxonomy alignment and identify
economic activity in accordance with the EU taxonomy (mitigation) in late 2022.
– To support its de-carbonization strategy and its fully-electric vehicles timeline, VW has
updated the framework’s eligible proceeds to include only capital expenditures for battery
electric vehicles, and explicitly excluding capital expenditures in relation to plug-in hybrid
electric vehicles or to vehicles with combustion engines.
– At VW, with the LCA assessment carried out, it has also initiated works to further improveits data integrity and identify hot spots in the LCA, where suppliers have been involved
early on, following which VW would then explore possible solutions to reduce the negative
impacts throughout the process.
Next Steps: Although green bond issuers from manufacturing intensive sectors such as
automakers generally report relatively high level of alignment on their green bond reporting
standards as compared to other sectors based on our findings, the level of disclosure still varies,
and many of them have yet updated the green finance framework to include EU taxonomy
activity details and alignment. VW is one of the early adopters in doing so with some areas of
improvements, and through our engagement, they have continued to improve their frameworkand green bond report. For the next steps, even though their allocation and impact reportare off to a strong start, we would ask VW to look into geographical breakdown of its green
bond project allocation and impact information to provide more context on local and regional
baseline and calculation reference. As EU taxonomy has been incorporated into its updated
Green Finance Framework, we would expect to see EU taxonomy reporting incorporated into
future green bond reporting. We are happy to see that VW has made steadfast contributions to
the development of green bond markets and we will continue our dialogue with the company.

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Looking Ahead - Advocating for Holistic Impact Data
Practices
Going forward we will continue to work withissuers and encourage best practice of having
a comprehensive view of their impact data, notjust operational level but also specific projects.
LCA is often based on ISO methodologies
and best practice, and many issuers that wehave observed work with professionals; suchas external consultants, external research or

academic bodies with specialty in this area,
to overcome certain challenges. System andtechnology are becoming more important as wellwhen it comes to data integrity and consistency.
We continue to encourage companies towork with external expertise where needed to
improve their data collection and transparency
across the value chain.

3. Thematic Engagement Activities ____________
A. Engagement on Thermal Coal: Transition to a Low Carbon Economy
Amundi’s Policy on ThermalCommitment to Coal Phase-Out

Coal

&

Amundi’s thermal coal policy remains a key partof its climate and engagement strategy. Without
a timely and accelerated wind down of thermal
coal globally, the world will be unable to reach
Paris-aligned temperature goals.
We have divested from coal developers and willcontinue to transition away from thermal coalin our portfolios. This will lead to a significant
reduction in financial support for companies
operating coal assets without strong phaseout plans in the next few years. Amundi iscommitted to phase out from thermal coal by2030 for OECD and EU countries, and by 2040
for the rest of the word. Our philosophy is thatcompanies need to contribute to the low carbon
economy by shutting down (not selling) coalassets and converting to clean energy while
taking into account the need for a fair transition.
At Amundi, divestment is a serious action so it isimportant to engage with companies at risk of
future divestment to make sure that our policy isclearly communicated and that companies haveadequate time to make the necessary changes
before possible exclusion. For companies near athreshold for exclusion, engagement is a way toensure that provider data is accurate in the caseof discrepancies due to differing calculation
methodologies. Engagement in this context canalso help Amundi make informed decisions prior
to possible divestment.

Engagement Selection
For the second consecutive year, we
communicated our coal policy to all companies
flagged for thermal coal in 2022 that we were
invested in, to encourage alignment with ourpolicy and to speed up the withdrawal fromthermal coal assets according to the 2030/2040
schedule, asking them to put in place a phaseout commitment by the aforementioned dates
if they had not done so already. Companies
selected for the engagement were based on thefollowing criteria:– Companies internally flagged for having
thermal coal based revenues (both coal
power generation and thermal coal mining
activities) ;– Companies where Amundi has exposure(both active and passive)– Companies within that list who have not
yet publicly expressed a commitment toexit from thermal coal in line with the Paris
Agreement adhering to the 2030/2040
timeframes
Engagement Objectives
Our key objectives for the engagement are as
follows:– Encourage companies to publicly commit
to a thermal coal exit in line with the Paris
Agreement (adhering to the 2030/2040
timeframes),– Encourage companies to develop targets and

20. Based on provider data and additional internal due diligence.

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October 2023

strategies around a thermal coal exit in linewith the Paris Agreement, and– Encourage companies to stop developing
new coal assets and capacity.

The policy is applicable to all investee
companies, but predominantly affects sectors
such as utilities, mining, industrials, oil and gas,
and transport infrastructure. Most are involved inthermal coal power generation or thermal coalmining activities due to their business models
that are significantly reliant on thermal coal.

➜ Our progress in 2022
Engagement Outcome & Issuer Momentum
Due to the merger with Lyxor, the number of issuers in our engagement campaign increased in
2022. The following table outlines the progress made by the companies that had already been
engaged by Amundi in 2021, prior to the acquisition:

Breakdown of Engagement Progress for Companies Exposed to Thermal Coal
2021 - 2022 OECD Issuers Evolution on Thermal Coal Exit Policy
OECD Issuers
100%
90%
80%
70%
60%
50%
40%
30%
20%

Issuers who exited Amundi’s thermal coal exposure list*

10%

Not aligned with 2030 Coal Exit Timeline
Aligned with 2030 Coal Exit Timeline

0%
2021

2022

2021 - 2022 OECD Issuers Evolution on Thermal Coal Exit Policy
Non OECD Issuers
100%
90%
80%
70%
60%
50%
40%
30%
20%

Issuers who exited Amundi’s thermal coal exposure list*

10%

Not aligned with 2040 Coal Exit Timeline0%

Aligned with 2040 Coal Exit Timeline

2021

2022

*either due to the company no longer having thermal coal exposure or Amundi no longer having exposure in thecompany

99 Stewardship Report 2022

Next StepsEngagement&

Amundi

October 2023

Perspectiveof

We will continue to engage on the subject ofthermal coal with all relevant investee companies
that do not have a timely phase-out plan. For
those where we do not see adequate actions
or movement in the right direction or at theright pace, we will continue to deploy a varietyof escalation tools including, but not limited to,exercising our voting rights as shareholders in
Annual General Meetings (AGMs). Depending
on how misaligned an issuer is with phasing out
by the 2030 or 2040 timeframes, we will takevarying approaches. Our actions range fromvoting against the discharge of the board to

voting against re-election of the chair or one ormore board members, as well as voting against
the re-election of the entire board. Exclusion
was also used in 2022.
In 2022, Amundi took voting actions against 29
issuers due to lack of engagement momentum
concerning thermal coal. Based on engagement
performance by 2022 year-end, we submitted
76 companies for voting escalation due to lackof reply to our engagements or lack of timely
phase out for the voting campaign 2023.
Further details of our escalation activities can befound in Principle 11.

Thermal Coal Phase-Out: Navigating the Insurance Sector's Role in
Climate Action
Engagement Selection

Engagement Outcome & Issuer Momentum

2022 marked the third year of Amundi's
engagement on coal policies, targeting adiverse range of insurers across geographiesand business lines. The breadth of this selection
led to varying developmental stages of coalexclusion policies among the engaged insurers.

2022 witnessed significant advancements inawareness and action. Over half of the engaged
insurers introduced tighter coal policies. A
pivotal achievement was the universal adoptionof some form of coal exclusion policy among all
engaged insurers. However, regional disparities
persist: while European insurers lead with refinedpolicies driven by increasing investor demands
and a vision for sustainability, Japanese insurers
move incrementally. American insurers displayed
mixed responses, with one announcing its
inaugural coal policy and another eventuallyaccepting dialogue after initial reluctance. The
table below provides a more in-depth overview
of our engagements focused on fossil fuelinsurance for three companies.

Engagement Objectives
Amundi's core demand revolves around theintroduction of a solid thermal coal policy,
considered an essential step for insurancecompanies aiming to align their underwriting
and investments with a 1.5°C or well-below 2°C
scenario. Key requirements include:– Explicit exclusion of coal developers,– A phase-out commitment by 2030 for OECDand EU countries and by 2040 globally,
mirroring the IPPC’s 1.5°C pathway, and– Introduction of progressive exclusion
thresholds to facilitate the full phase-out.

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2022 Engagement Campaign Overview – Fossil Fuel Insurance
Assessment at
Company start of campaign(2020)

Recommendations
in year 1 (2020)

Achievements over Achievements
2020-2021
in 2022

Changeduring
2022

Quality of
Recommandations
thermal coal
during 2022
policyA

No policy- Formally publish acoal exit policy.

Divestment from all
direct investments inbusinesses with>30% of income
from coal, withequities to be fully
divested by the endof 2021 and
fixed-income assets
by the end of 2022.

No evolution of policy- Introduction ofabsolute thresholds.
- Exclusion of coaldevelopers.
- Define a full phase outplan.
- Extend the coal policy
to its third party
assets.

B

No policy- Formally publish acoal exit policy.

- Divestment and/or
run off of directly
managed equity
and fixed income
exposure to coalmining andcoal-fired powerbusinesses, by theend of 2021 forequity and 2028 forfixed income;- Not permit any new
investments inbusinesses involved
directly in either
mining coal or
generating
electricity fromcoal.

No evolution of policy- Exclusion of coaldevelopers.

C

No policy- Formally publish acoal exit policy.

No evolution of policyFirst announcementof a policy- No longer invest or
insure theconstruction of any
new coal-fired
power plants,
thermal coal minesor oil sands;- No longer invest or
underwrite new
operation
insurance risks ofcoal-fired power
plants, thermal coalmines or oil sands
for clients with >30% of theirrevenues fromthese industries, or
generating > 30%of their energy
production fromcoal;
- Phase out theunderwriting of allexisting operation
insurance risks andceasing newinvestments inclients with > 30%of their revenues
from coal-fired
power, thermal
coal mines or oilsands, or
generating > 30%of their energy
production fromcoal by Jan. 1,
2030, or sooner;and- Not investing in orprovidinginsurance cover for
any new Arctic
energy exploration
activities.

- Exclusion of coaldevelopers.
- Introduction ofabsolute thresholds.
- Define a full phase outplan.

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D

(General account)
investments:
Exclude companies- deriving >30% ofrevenues or energy
production fromcoal,
- producing >20m
tonnes /year of coal,or- actively involved inbuilding new coalfacilities or plants.
Policy includes
exceptions forheavily coal-dependent countries.
Engaging with thesix coal companies
remaining.

October 2023

- Remove theexception forheavily coal-dependent countries.
- Extend the policy
to its third party
assets.
- Clearly define a fullphase out plan.

(General account)
investments:
Exclude companies- deriving >20% ofrevenues or energy
production fromcoal;
- extracting >10m
tons /year of coal;- with an installed
coal power
capacity of >5GW,or- actively involved inbuilding new coalcapacity of>0.3GW.
Full phase out ofinvestments by 2030
in OECD and by
2040 in rest of theworld.

No longer investingin companies with
>5% of revenue fromtar sands andoperators ofcontroversial tar
sands pipelines.

Companies withdecarbonisation orcoal phase out
strategies alignedwith a 1.5°C pathway
will not be excludedby the newthresholds, unlessthey are developing
new coal capacity.

Underwriting:No insurance forconstruction of new
coal-fired power
plants or new coalmines, or forcoverage of existingcoal-fired power
plants if they belong
to new customers.

- Removal of "Forissuers in countries
heavily dependent
on coal, when there
is no evidence of aclear decarbonization strategy or of a
gradual coal phaseout, a dedicatedengagement is
implemented".
- Extension of coalmining developers.

- Extend the exclusion ofcoal developers tocover developers ofcoal infrastructure (ontop of coal power
plants and coalmining).
- Extend the coal policy
to the remainder of its
third party assets.

Underwriting:No insurance for theconstruction of newcoal mines and newcoal-fired power
plants, even forexisting clients(except formodernization or
retrofitting
exercises).
No property
coverage for existingcoal mines ofpotential new clients.

For issuers incountries heavily
dependent on coal,when there is noevidence of a clear
decarbonisation
strategy or of a
gradual coal phaseout, a dedicatedengagement is
implemented.

Continues not tounderwrite risks ofcompanies operatingin the tar sands
sector.

Underwriting:No underwriting ofcompanies
generating >5% ofrevenue from tar
sands and operatorsof controversial tar
sands pipelines.
Reduce exposure to
zero by 2030 inOECD and by 2038 inrest of the world.

E

Exclude underwritingof and investments
in companies with>25% of extraction,
production orrevenues fromthermal coal.
Phase out of existingrisks by 2023.
Commitment inprinciple to notprovide insurance
for, nor makeinvestments in newcoal-fired power
plants.

- Earlier phase out ofexisting risks.
- Introduction of an
absolute threshold.
- Exclusion of coaldevelopers.
- Clearly define a fullphase out plan.

No evolution of policy

No evolution of policy- Introduction ofabsolute thresholds.
- Exclusion of coaldevelopers.
- Define a full phase outplan.
- Develop an exclusion
policy on tar sands.

F

Commitment inprinciple to notprovide insurance
for, nor makeinvestments in newcoal-fired power
plants.

- Remove reservationon the exclusion of
new coal plants.
- Adopt an exit
policy for existingcoal plants andcoalmines.
- Clearly define a fullphase out plan.

Will not provide
insurance for, nor
make investments in
new coal-fired power
plants.

Addition:
Not newly provide
insurance for, nor
make investments inthe existingcoal-fired power
plants or steam coalmines.

- Removal of exclusion("However, we may
carefully consider andhandle the cases thatincorporate
decarbonizing
technologies andtechniques towardachieving the Paris
Agreement targets.")- Exclusion of coaldevelopers.
- Adopt an exit policy forexisting exposure.
- Define a full phase out
plan.

However, may do soafter prudent
consideration forcases where suchplants are essential
for the stable supplyof energy to thecountry concerned.

However, we may
carefully consider
and handle the casesthat incorporate
decarbonizing
technologies andtechniques towardachieving the Paris
Agreement targets.

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G

No new insurance or
new financing forcoal fired power
generation projects.
But including
exceptions forindividual
circumstances:“circumstances suchas national energy
policy and otherconsiderations in therelevant country, andin the context of theOECD Arrangement
on OfficiallySupported Export
Credits and otherinternationalguidelines” and “willalso take into
account otherfactors such as theavailability of otheroptions andalternativetechnologies”.

H

Exclusion ofcompanies with>20% revenues
related to coal andlignite, or>50% revenues
related to coal-fired
electricity
production, or>20% revenues
related to tar sands
and oil shale.

October 2023

- Removereservations on the
exclusion of coal
fired power
generation projects- Extend the policy
to coal mining andcoal infrastructure
projects as well as
all coal-relatedcompanies.
- Adopt an exit
policy for existingcoal exposure.

No new insurance or
new financing forcoal fired power
generation projects
or thermal coalmining projects.

- Introduction of an
absolute threshold.
- Lower the 50%
threshold forcoal-fired power
plants.
- Clearly define a fullphase out plan.

Exclusion ofcompanies with:any revenue from themining of thermalcoal, or>20% revenues
related to coal-fired
electricity production,or>5% revenues fromthe exploration andextraction of
unconventional oil
and gas (shale oil andgas, oil shale, tar
sands and arctic oil).

However, we may
grant exceptions for
projects with
innovativetechnologies andapproaches, such as
CCS/CCUS andmixed combustion,with the aim ofachieving the goalsof the Paris
Agreement, based on
careful consideration.

Addition:
No new insurance or
new financing for oil
and gas company
extraction projects*
in the Arctic Circle(all areas north oflatitude 66°33,
including the Arctic
National Wildlife
Refuge, ANWR) andoil sands mining.

- Removal of exceptions.
- Extend the policy tocoal infrastructure
projects as well as allcoal-relatedcompanies.
- Exclusion of coaldevelopers.
- Adopt an exit policy forexisting coal exposure.
- Commit to a full phaseout (according to a
2030/2040 timeline).

*Exemptions for projects
with decarbonizationplans that are alignedwith the Paris Agreement

No evolution of policy

For coal-fired electricity
production:- Introduction of an
absolute threshold.
- Commit to a full phaseout (according to a
2030/2040 timeline).

Exit from and no
new investments incompanies:- with >15% ofrevenues from coal
extraction orcoal-fired power
generation(with revenues
between 15% and
30% possible inindividual cases,
where an active
engagement
dialogue has been
established withthe company)- with >10% ofrevenues from oilsands.

- Phase out from thermal
coal for OECD
countries by 2030
instead of 2040.
- Apply the restriction"No insurance for new
coal power plants,
mining and related
infrastructure" to theTreaty reinsurance
business also.

Applicable to its
general andthird-party accountassets - except funds
from external
providers.

I

Applicable to its
general andthird-party accountassets - except funds
from external
providers.
Exit from and no
new investments incompanies with- >30% of revenues
from coal
extraction orcoal-fired power
generation,- >10% of revenues
from oil sands.

- Advance the phaseout from coal forOECD from 2040
to 2030.
- Extend the coal
policy to the treaty
reinsurance
business.

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October 2023

Amundi's Strategic Engagement with Banks on Coal Phase-Out
Initiatives
Amundi has been proactive in its engagementwith major banks to advance the phase-outof thermal coal and promote alignment withclimate-centric goals. Through persistentdialogue, Amundi emphasises the importanceof banks adopting clear, actionable pathways
towards net-zero emissions. These engagements
have led to meaningful progress, with banks

committing to detailed sustainability strategies,
disclosing absolute financed emissions, andunveiling policies that restrict the financing
of coal-centric activities. By leveraging
collaborative investor coalitions and individual
follow-ups, Amundi has played a pivotal rolein steering the banking sector towards a moresustainable future.

Case study 16: Driving Thermal Coal Phase-Out Through Collaborative Engagementwith HSBC
Context: Amundi has been engaging with HSBC for several years on the topic of climate andits thermal coal policy. HSBC had committed to reach Net Zero emissions by 2050, but apathway on how it would reach this target was missing, as well as a clear plan to phase out
coal investments. Following intensive engagement with HSBC though a collaborative investor
coalition led by ShareAction, the bank committed to disclose a sustainability strategy. This
strategy included an alignment of its financing activities with the objectives of the Paris
Agreement and a phasing out of thermal coal by 2030 in the OECD and by 2040 in the restof the world.
Amundi Actions: Under the ShareAction banner, Amundi was part of a group of large investors
that filed a climate resolution with HSBC in January 2021, ahead of its AGM. Following this,
HSBC itself filed a board-backed resolution at the 2021 AGM committing the bank to disclose asustainability strategy. On the back of this company-proposed resolution, the co-filing investors,
including Amundi agreed to withdraw their motion and instead supported the bank’s proposal
during the AGM in May 2021. In late 2021, Amundi individually followed up with HSBC following
the release of its thermal coal phase-out policy. Even though we considered that HSBC had
made good progress during 2021, we believed that a major issue was still not addressed.
In particular, our key objectives for HSBC in 2022 included:– expand the thermal coal exclusion policy to its asset management activities.
– refinement of the coal developers’ definition, to ensure the exclusion of indirect financial
support for new thermal coal assets.
Towards the end of 2022, we were asked to provide feedback prior to the publication of
its revised energy policy, which was published in December. However, it was not clear whatassurances HSBC would seek to ensure that general corporate purpose financing is not used
for activities which the new energy policy is trying to exclude.

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October 2023

Engagement Outcomes and Issuer Momentum:
Following the announcement of HSBC’s 2021 climate strategy, we observed further momentum
during 2022, including the following key developments:– The bank disclosed absolute financed emissions for two sectors and disclosed
decarbonisation targets for lending activities related to these sectors in February 2022,– The bank published a thermal coal exclusion policy for its asset management activities in
September 2022,– The bank published an updated energy policy in December 2022, which included an
exclusion on provision of new finance or advisory services for the specific purposes of new
O&G fields or related infrastructure.
Next Steps:
We will continue to engage with HSBC. In particular, Amundi has asked for a refinement of thecoal developers’ definition, to ensure the exclusion of indirect financial support to new thermal
coal assets.
More details on our collaborative approach to engagement can be found in Principle 10.

b. Engagement on Biodiversity & Natural Capital Preservation
Background & Amundi’s Policy on Biodiversity
Biodiversity encompasses the variety of
ecosystems on Earth and is crucial for theplanet's health, human well-being, andeconomic stability. Currently, we are witnessing
a concerning decline in biodiversity, with one
million species facing potential extinction. Thisdecline poses multifaceted risks, from threats
to food security and public health, to increased
severity of environmental disasters, which inturn jeopardises the stability of corporates
and society. In 2022, the Kunming-Montreal
Global Biodiversity Framework highlighted
the essential role financial institutions must
play, both in mobilising funding and engaging
with corporations. Investors need to ensurethat companies align their ambitions with theframework's targets, thereby mitigating theassociated risks.
Amundi recognises the urgent need to address
biodiversity loss. Our engagement strategyemphasises the importance of corporate
responsibility in addressing their biodiversity
impact and understanding the risks stemmingfrom their reliance on nature. We advocate fora proactive approach that includes addressing
significant contributors to biodiversity loss, suchas pollution, deforestation, and unsustainableconsumption. The pathway to incorporating thegoals of the Global Biodiversity Framework into
actionable corporate strategies is still unfolding,but the urgency to act is evident.
Engagement Selection
The initial pool of companies we engaged on
biodiversity included 56 corporates acrosseight sectors and 18 countries (see our 2021
engagement report for more details). They
operate in sectors such as restaurants, mining
and metals, chemicals, and insurance. In 2022,
we grew our engagement pool to 92 issuers. The
broad nature of the initial engagement sample
meant that we could identify best practicewithin and across sectors and geographies, anduse this as guidance for companies. Details onthese practices can be seen in our standalone
report (found here). In 2022, we followed up
with corporates to re-emphasise Amundi’s
recommendations.
Beyond our initial engagement pool, biodiversity
was a topic of engagement for other companies
in 2022, with whom we shared the our learnings
from 2021.

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October 2023

Engagement Objectives
Our key objectives for the engagement were as
follows:– Raise awareness of the growing topic of
biodiversity loss to accelerate corporate
action– Identify current industry best practice anddisseminate these recommendations tocorporates.

➜ Our progress in 2022
Engagement Outcome & Issuer Momentum
In 2022, we observed a few examples of companies that have already made improvements totheir biodiversity strategy:
SectorCompany A
Sector:Consumer
Services
Country:
UnitedStatesCompany B
Sector:Mining &MetalsCountry:
Australia

Company C
Sector:Chemicals
Country:
UnitedKingdomCompany D
Sector:Food
Products
Country:
UnitedStatesAssessment at startof campaign (year 1)

Past Recommendations(Year of current
engagement -1)

Status in 2022

ChangeAdditional
Recommendations
going forward- 2030 Zero deforestationcommitment and alreadyachieved nearly 100%transparency for key
commodities- Biodiversity integrated into
conversations on environmental risks but no specificstrategy- Involved in numerous
collaborative initiatives on
key commodities- Lack of policy on antibiotic
use that complies with WHO
guidelines- More transparency onsustainable sourcing
beyond key commodities- More transparency andproof points on external
collaborations to further
their goals and targets- Improve commitments on
antibiotic use- Public indication that internal
focus has now expanded to othercommodities beyond key ones tomeet 2030 zero deforestation
goal (though little reporting on
the progress for these yet)
- Public disclosure on biodiversity
specifically including an
indication that they are in theprocess of developing aframework to guide their efforts(with TNFD)- Lack of policy on antibiotic usethat complies with WHO
guidelines- Establish antibiotic
policy that complies
with WHO Guidelines- Improve reporting on
zero deforestation
target beyond key
commodities- More reporting on
biodiversity frameworkthat is in development- Time bound (2030) No Net
Loss strategy for biodiversity- Biodiversity monitoring at site
level using available tools like
IBAT
- Extensive collaboration withexternal groups- Early days of risk modeling toincorporate biodiversity into
their models- Develop companywide
biodiversity strategy (notjust looking at the topic at
an asset level)- Improve biodiversity
reporting to provide
greater transparency on
their efforts to calculate
their no net loss ambition- Provide clearer biodiversity
roadmap- Report on company
impacts, dependencies,risk, opportunities- Published short term milestones
for their healthy environment
goal which will include context
based water targets- Completed all mapping for land
and water areas and theestablishment of nature positive
asset plans to work towards their2030 goal- Publish more details on
nature positive asset
plans- Report on impacts,
dependencies, risks,
opportunities linked tobiodiversity- Target to be Land Positive by
2030- Topic overseen by executive
committee- Science based approach toassess biodiversity footprint- Considers downstream andScope 3 impacts of products- Further develop thebiodiversity strategy,
notably by incorporating
further other drivers of
biodiversity loss than land
use change- Develop other biodiversity
related indicators andtargets- Net Nature Positive by 2030 (inaddition to previous land positivecommitment)- Follow through on commitmentby preserving and restoring
natural ecosystems in supply
chain, minimising water impactof operations and helping toaccelerate regenerative andsustainable agriculture- Further detail thereporting on company’s
impacts, risks,
dependencies, andopportunities related tonature- Expand further the LCA
in order to further cover
the product portfolio- Biodiversity is part of theenvironmental strategy of thegroup but not a distinct topic.
- The company has establishedan action plan in favour ofagro-forestry which isadapted to regional
specificities- The company has set up a
programme “Harmony” withc.2,000 wheat farmers in
Europe with a specific aim of
the protection of biodiversity
and preservation (ie via
counting bees and butterflies
at sites); there is a charter of
35 farming practices thatneed to be adhered to.

- Better formalise thebiodiversity strategy as a
distinct theme within theenvironmental strategy- Public reporting on specific
KPIs as they relate tobiodiversity and theconservation projects thathave been introduced at
the company.

- Since last year the company has
become more involved withsustainability initiatives related toland and forest restorations andregenerative agriculture- Expansion of the “Harmony”
wheat programme; and all wheat
required for the European
biscuits division will now be
produced under Harmony.
- Cocoa Life programme includes
biodiversity considerations – forexample land restoration
initiatives across Cote d’Ivoire
and Ghana.

- Public disclosure of KPIs
that relate to theHarmony programme
including, % of farmers
complying with theprogramme, # species
measured at farms- Detailed definition of themeaning of “responsible
pesticide use” at thecompany

Next Steps & Amundi Perspective of Engagement
In order to allow companies sufficient time to take our recommendations into account, a formal
follow up will occur in 2023. We will reassess company performance using our proprietary
methodology (described in the standalone report). We will continue to widen our engagement
pool on this topic.

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Case study 17: Sodexo's Journey Towards Biodiversity Conservation
Context: Amundi started engagement with French catering company Sodexo on biodiversity
in 2021. Biodiversity loss is a particularly tough subject for a catering brand with global
operations because sourcing decisions are not made centrally, but at the local level. This makes
it difficult to systematically implement companywide targets. Sodexo has a zero deforestationcommitment in place and had set a science-based target to align with the 1.5 degree scenario;
commitments that would profoundly impact how they do business. The company also has a2025 target for their menus to include 33% plant-based dishes. However, the company was still
very much in the early days on the topic of biodiversity more broadly.
Amundi Actions: After initial engagement in 2021, Amundi followed up in 2022 with formal
biodiversity recommendations for the sector. This included anonymised guidance on how
they currently scored in comparison to sector peers, as well as Amundi suggestions for bestpractice.
Key objectives for Sodexo were:– Achieve full transparency and mapping of supply chain,– Develop a global biodiversity policy that includes guidance on how this is to be translated
at a local level,– Top down reporting on biodiversity (taking local progress and KPIs and aggregating it forinvestors),– Expand their biodiversity-linked strategies to beyond core commodities (i.e. soy andseafood) and impact drivers (food waste, plastic packaging), and– Collaborate with industry peers to address biodiversity loss.
Engagement Outcomes and Issuer Momentum:
In 2022, we observed positive developments at the company in that Sodexo joined the
Act4Nature initiative, which reinforced their ambition to develop responsible agriculture basedon the preservation of natural resources and the respect for biodiversity. Sodexo’s Act4Naturecommitments are the same ones described above but in a key development, they haveclassified them according to the drivers of biodiversity loss from IPBES, 2019. We see this as a
key clear indicator that Sodexo is thinking more holistically about environmental targets within
the context of a global biodiversity strategy.
Next Steps: Going forward, we hope to see more collaboration from Sodexo with industry
peers, such as those within Act4Nature, to accelerate change. We hope to gain a better
indication of how public targets are being translated at the local level, in particular for morechallenging geographies. We also hope to see more transparent reporting against Sodexo’s
other commodities beyond the five priority ones. However, we understand these objectives
could take a few years and look forward to following up annually on their progress.

c. Engagement on Social Cohesion: Protecting Employees andPromoting Human Rights
Context:
At Amundi, we understand that transitioning
to a sustainable low-carbon economy may
lead to social tensions, impacting a wide rangeof stakeholders and potentially hindering our
climate objectives. We believe in a holistic

approach that values both the destination andthe journey towards a decarbonised economy.
To counter broader inequalities, we emphasise
the importance of fostering innovation andachieving economic stability by ensuringrespect for fundamental human rights, not only

107 Stewardship Report 2022

within our direct operations but throughout
our supply chains. We have initiated campaigns
against the global increase in forced labourand have championed methodologies toprevent forced and child labour. Moreover, we
are advocates for a living wage, emphasising
the welfare of workers and the importance ofgiving employees a voice. While we continue toOctober 2023

engage on gender equality, we have expanded
our focus to disability inclusion, recognising its
potential in accessing untapped talent pools.
Through collaboration, we have participated inseveral campaigns and initiatives to promotesocial cohesion, always highlighting the need forcomprehensive reporting on social challenges.

Amundi’s Policy on Engaging on Gender Diversity at the Board Level
Amundi champions the principle of diversity,
understanding its critical role in fosteringwell-rounded decision-making, especially as
businesses navigate increasingly complex
landscapes. We advocate for companies tocultivate gender diversity and inclusivity, witha particular emphasis on diversifying board
compositions. While our global engagement
campaigns sometimes face nuanced challenges,
such as shifting focuses from gender to ethnic
diversity in markets like the United States, westand firm in our belief that gender diversity
efforts should remain undiminished. Prioritising
ethnic diversity should not overshadow thesignificance of gender representation. In
Asian markets, we continually underscorethe importance of diversity as a core investor
concern. Thankfully, with more investors echoing
our stance, we're witnessing positive shifts inthe discourse.
Engagement Selection
Amundi’s Corporate Governance team has
systematically discussed gender diversity withcompanies, across all geographies, whenever aconcern was identified.
Given the lack of progress of some companies
on this issue, we decided to escalate the matterand initiate a proactive dedicated campaign on
the topic. To define the scope of this campaign,
we identified issuers for which we have exercised
our voting rights on the first semester of 2022
and for which we have voted against somedirectors’ re-election due to lack of gender
diversity (33% of women for developed markets
and at least one woman for Asian and emerging
markets). On this primary scope, we decided tofocus on the Amundi’s top holdings per region.
During Q3 2022 Amundi sent 128 letters toboard chairs, across all markets and sectors, to
ask them to improve female representation andto warn them of potential dissent votes from
Amundi at their 2023 AGM if improvement or
progress was not seen.
Engagement Objectives
Amundi expects companies to take steps toensure that each gender represents a minimumof 33% of the board for developed markets. As amember of the 30% Club Investor Group France,
Amundi also aims to increase the representationof women in executive management teams
to reach at least 30%. In Asian markets, thenature of the dialogue differs, as this is still an
emerging topic. Taking into account this market
difference, we are asking for at least one woman
to sit on the board in this region.

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➜ Our progress in 2022
Engagement Outcome & Issuer Momentum
As of the 31st December 2022, 43% of target companies answered our letter. More than one
third (19 companies) acknowledged receipt of our letter without providing any supplementary
information, a quarter showed a real interest in the topic, with some already defining a strategy
or taking a commitment to improve their level of gender diversity. Amundi is pleased to notethat four issuers have already increased the number of women at board level and are nowaligned with Amundi’s expectations. The chart below illustrates our engagement efforts
towards increasing female representation at the board level for two companies.
Macro
SectorAssessment at startof campaign (year 1)

Company A

Low rate of female representation at the board level (27%)

Sector:Banks

Past Recommendations(Year of current
engagement -1)
Increase female representation at the board level to
33%

Sector:Pharmaceuticals• Company acknowledged issue and committed to reaching
33% by the year end• Company appointed a woman as new independent board
member and her nomination will be on the next AGM
agenda in 2023

Country:
Spain
Company B

Status in 2022

No female representation at
the board level at the 2022
AGM

Appoint at least one female
director• company informed us that they did recognize theimportance of board diversity under the current social andbusiness environment• informed
Amundi that one of the key initiatives in 2022
Illustration
18: Amundi’s Disability Inclusion Engagement
Campaign
Country:
would be to identify and appoint a female member
Hong Kong

Disability inclusion is a pivotal aspect of the social dimension in ESG, a segment thatencompasses a broad spectrum of diversity, equity, and inclusion (DE&I) issues. While areas
like gender equality and ethnic diversity often receive attention, disability inclusion remains
less explored, even though the World Health Organisation estimates that approximately 15% of
the global population lives with some form of disability.
Embracing disability inclusion in the professional world is not merely about rights and justice;
it is a catalyst for sustainable growth and development. According to the report “Unlock thecompetitive advantage of a disability-inclusive workforce,” there has been a notable shift
in perception: companies are transitioning from viewing disability inclusion as just a CSR
obligation to recognising it as a solution to talent shortages and a means to facilitate businessand cultural transformation.
At Amundi, and more broadly, within Crédit Agricole, we hold the conviction that disability
inclusion is integral to advancing the overarching themes of DE&I. Ensuring equal occupational
opportunities for everyone is a core tenet of our philosophy. As responsible investors, we see
it as our duty to highlight, educate, and promote disability inclusion strategies across various
companies and sectors, prompting the inception of our Disability Engagement Campaign in
2022.

Illustration 19: Overview of Amundi’s Cross-Sector Engagement
Inclusion of persons with disabilities is a topic that concerns all sectors. Still, the challenges
and practicalities are different depending on the type of industry, whether it concerns a
production or a services sector. For this engagement theme we have therefore deliberately
chosen to include sectors with a different degree of production intensity and service level:
TMT, healthcare, consumer, industrials and financials. Overall, we contacted 67 issuers, of which
84% participated in the engagement (56 companies).

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Companies engaged on Disability Inclusion
Industrials

Non-Participants
Non-Participants

11

Industrials

8

11
Financials

56

56

Healthcare

8

Financials

8

10
Healthcare

8 24
10
17

Participants

24
TMT

17

Participants
Consumer

Consumer

Source: Amundi Asset Management

Engagement Objectives
As this concerns the first year of engagement, the purpose of the 2022 campaign was:– to gather more detailed information about the state of the global jobs market in terms of
disability inclusion;– the identification and dissemination of best practice.
During this campaign, we gave broad feedback to corporates. Going forwards, we will use themore in-depth insights derived from the campaign to provide companies with more concrete
feedback to facilitate increased action around disability inclusion.

➜ Our progress in 2022
Engagement Outcome & Issuer Momentum
We noted from this engagement campaign that companies very often have a disability strategy
in place, but that in some cases these strategies turn out to be a ‘box ticking’ exercise. We will,
therefore, remain vigilant and ask companies for concrete examples of implementation andtheir progress. Below are some of the key insights we gathered from this campaign.
– While many companies have a broad DE&I strategy, dedicated disability inclusion strategies
are less common,– National regulations significantly influence the strength of disability policies, withcountries like the US, France, and Japan leading in disability integration due to reporting
requirements or aspirational goals,– Few companies publicly communicate the percentage of disabled employees. However,there is a growing trend, especially in the US, towards "self-identification" of disabilities by
employees,– Cultural barriers and regulations, especially in European countries, hinder self-reporting of
disabilities,– Companies are increasingly fostering a disability-inclusive culture through various
initiatives, including Employee Resource Groups and DE&I Champions,– Many companies participate in global initiatives like the Disability Equality Index of
Disability:IN and the Valuable 500 group, and– A notable perspective from an engaged company promotes use of the term "uniquelyabled" instead of disabled.
Below is a case study of Amundi’s engagement with NTT, a leading telecommunication company,
recognising its proactive approach to disability inclusion, particularly in hiring practices anddedicated projects.

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Case study 18: Engaging on Disability Inclusion with NTT
Context: Disability inclusion receives less attention than other DE&I topics, such as genderequality and ethnic diversity. However, approximately 15% of the global population has someform of disability. By attracting and retaining this workforce, telecommunication companies
increase the size and diversity of their talent pool in terms of competencies and perspectives.
We believed NTT to be a great example.
Amundi Actions: Amundi started engaging with Nippon Telegraph and Telephone Corporation(NTT) in 2022, alongside the launch of our Disability Inclusion campaign. During the campaign,
we noticed that companies most often simply add a section on disability to their existing DE&I
policies, rather than establishing a distinct policy or strategy. NTT, however, has implemented
a set of measures specifically focusing on disability. This made the company a ‘best in class’actor among our engagement universe.
Engagement Objectives: During this first year of the engagement campaign, we primarily
focused on the gathering of information and the identification of best practice. Nonetheless,the meetings also allowed us to give some initial feedback to corporates. Overall, our objectives
going into the engagement were the following:– Insure dedicated monitoring and resource allocation for Disability– Improve communication around disability inclusion strategy– Encourage collaborative initiatives and communicate best practices.
Engagement Outcomes and Issuer Momentum: We believe NTT’s progress on disability
integration is a reflection of the Japanese government’s proactive stance on this topic. Notably,
the group includes disabled people in its workforce directly as well as through four Special
Purpose Vehicles (as Japanese law allows it). Most recently, disabled employees at NTT's
domestic group companies represented 2.47% as of June 2022 (above the legally required
rate of 2.3%).
NTT has many projects that have been built to realise the potential of disabled employees.
For example, people with disabilities analyse the accessibility of websites and suggest
improvements in accordance with Japanese Industrial Standards (JIS). Disabled employees
also deliver lectures and training sessions at a wide range of events to help others better
understand disability. Additionally, NTT operates a portal site (Yu Yu Yu), which serves to help
disabled and elderly people. Another example concerns internal consulting services provided
by disabled employees, working in coordination with NTT Laboratories, to verify technologies
and services from the perspective of people with disabilities.
Finally, we also value NTT’s membership (since December 2019) of the Valuable 500, aninternational initiative to promote the participation of people with disabilities in business.
Broadly speaking, NTT is quite advanced on the topic of disability inclusion into the workplace.
However, NTT does not yet monitor the financial resources allocated to disability inclusion. We
recommended the company allocate and report on a specific budget for disability inclusion.
Next Steps: We will follow up with the company next year. Among other points, we willencourage NTT to have specific resources allocated to disability inclusion at group level, suchas a dedicated team and a specific budget, on top of the existing Diversity Promotion Officers
in charge of disability and diversity inclusion.

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D. Just Transition Engagement Campaign
Context:
Transitioning to a low-carbon economy isunlikely to succeed if the social risks associatedwith the changes are not properly managed.
Key to a just transition is the commitment
to leaving no one behind and ensuring thatadverse effects of the transition are mitigatedfor workers, local communities and other socialgroups; while providing decent work for all,promoting social inclusion and eradicating
poverty. These principles are enshrined in the2015 Paris Agreement and the guidelines issued
by the International Labour Organisation in thesame year.

risks associated with the transition. The initial2020 engagement started with the transport
sector, particularly with automotive companies
whose business models had started to evolvewith the growing demand for electric vehicle(EVs), necessitating new employee skill profiles.
In 2022, we also engaged with companies in theextractives sector on their approach to a justtransition. For example, for various companies
within our thermal coal policy engagements(see page 96 of this report for more details),
a Paris-aligned thermal coal exit cannot andwill not happen without a clear just transition
strategy.

Failing to adhere to the objectives of justtransition entails material risks for companies
and the wider society. A disorderly approach totransition that does not incorporate the principles
of social protection is likely to exacerbate
societal inequalities and pose risks to the global
economic system, fueling poverty and community
displacement. It also risks undermining support
for environmental objectives if the affectedstakeholders see themselves as disenfranchisedand disadvantaged by the changes. From an
operational and reputational risk standpoint,
companies can face disruption and legal
challenges from workers who have not beenoffered reskilling or decent jobs, or communities
whose livelihoods are affected by closing sites.

Engagement Objectives

To achieve the goals of advancing decent workand promoting decent work in accomplishing
the environmental transition, companies needto:– Respect human rights and promote equity,– Engage workers and stakeholders in social
dialogue, and– Assess risks, allocate resources and conduct
adequate planning for transition forworkers (e.g., by identifying reskilling andredeployment opportunities) and affected
communities and customers.
To support corporate action on supporting ajust transition, Amundi began engaging withcompanies on this issue in 2020.
Engagement Selection
Our sector selection for this engagement
campaign was driven by exposure to the social

The overall objective of our engagement is toencourage companies to incorporate a justtransition into their climate plans by:– Assessing estimated transition risks on
workforce and relevant stakeholders, suchas local communities, and quantifying suchrisks where possible through metrics such as
number of jobs affected or number of sites
marked for closure,– Implementing and demonstrating evidence ofadequate social due diligence, dialogue andstakeholder engagement mechanisms,– Developing an explicit just transition strategy
to align with climate, net zero, and thermal
coal policies and strategies, and– Developing and demonstrating appropriate
risk mitigation plans, such as allocationof budget for workforce reskilling andredeployment.
Next StepsEngagement&

Amundi

PerspectiveofOver the course of our engagement, we haveseen growing awareness of just transition
among companies with whom we have held
dialogues. However, corporates’ understandingof the social obligations that come with a shift
towards more sustainable business models
remains fragmented. In 2023, we will seek toengage with additional sectors and increase
the geographical coverage of our engagement
efforts to include more emerging market
companies.

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Case study 19: Update for 2022 – Large car manufacturer’s Just Transition in theAge of Electrification
Context: The automotive industry is witnessing radical shifts propelled by electrification andautomation. With these changes come significant workforce implications, necessitating wellstructured transition strategies. A major player in the automotive world with over 660,000 global
employees, is at the forefront of these transitions, committing €33 bn to its electric vehicle (EV)venture in the coming years. As the sector transformation continues, the player is under the
microscope to ensure that the shift towards EVs does not leave its massive workforce behind,especially since the company historically boasts strong employee development programmes.
Amundi Action: Recognising the emerging challenges tied to a ‘just transition,’ Amundi
engaged the car manufacturer for a clearer roadmap. Key objectives in 2022, continuing from2021, included:– Publicly reporting training needs that align with the forthcoming just transition, identifying
both obsolete roles and future skill requirements,– Enhanced transparency on transition-specific training, including the effectiveness metrics(KPIs) utilised, and– Greater clarity on HR’s strategy to manage potential redundancy bottlenecks, especiallywith the impending shift to EVs.
Engagement Outcomes and Issuer Momentum: The car manufacturer has shown positive
strides. In 2020, the company committed to avert major redundancies until 2029, with thebulk of job reductions coming from natural retirements. This commitment was reinforced byan agreement between company’s union and management for a socially harmonious futuretransition.
Furthermore, in 2022, the company provided insights into its workforce composition, noting that
half of its employees still work manual jobs. As the company accelerates its digital and electrictransformation, an academic collaboration has been initiated to pinpoint areas of workforce
impact and requisite skills development. Emphasising future-readiness, the car manufacturer
has committed to focusing its employee training on crucial emerging technologies.
While these steps are commendable, the company is still shaping its comprehensive justtransition strategy. In comparison to 2021, the company displayed greater receptiveness toenhancing its disclosure, albeit without detailing the precise employee impact metrics or acomprehensive mitigation strategy. However, as part of its ‘NEW AUTO Group strategy,’ thecompany has emphasised the importance of training, aiming for a 35% increase in training hours
by 2030, a step towards addressing potential human capital discrepancies in the electrificationera.
Next Steps: In 2023, Amundi’s engagement with this car manufacturer will remain robust. The
focus will be on urging the company towards a detailed just transition strategy coupled withmeticulous disclosures.

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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/or signatory. We are an active
participant in working groups at a range of organisations – both regulatory and industry-led– aimed at moving responsible finance, sustainable development and corporate governanceforward in the best interests of our clients.

1. Collaborative engagement: working with our peers
to help drive the conversation
Collective efforts can have 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. 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 we might wish.
Amundi values both engagement types as amean to have a positive impact on sustainableoutcomes.
Amundi often plays an active role in collaborative
initiatives. We generally take the role of lead
investor on engagement with one or morecompanies. Sometimes an ‘active role’ alsomeans 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. Thisis usually 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 provide 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 active engagement.
International initiatives can include both
institutional investors and asset management
professionals. The goal is to encouragebusinesses to improve their practices andtransparency in terms of, for example,
combatting climate change and deforestation,
protecting water resources, and health andnutrition in developing countries. 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.

– Chair of the engagement
commission

With other SIFs (Sustainable
Investment Forum), the French
SIF is a founding member of theEuropean network, Eurosif.
Association Française dela Gestion financière

Responsible
finance

Professional body

– FIR- AG CAC 40: Active
participation in drafting ESG
questions at CAC40 companies’
AGMs as well as to the analysis of
the answers and the report– Member of the working group on
forced labor in collaboration with
RHSF to create a methodology– Amundi co-headed theworking group that led to the
publication of guidelines to asset
management companies forsetting a fossil fuel policy for theoil & gas sector– Working group on gender
diversity and disability

ICMA - International
Capital Market
Association

Responsible
finance(Green Bonds Principles,
Social Bonds Principles
and Sustainability-Linked
Bond Principles)

Institut de la FinanceDurable (IFD, the Paris
Institute for Sustainable
Finance, formerly Financefor Tomorrow)

Global Investors for
Sustainable Development
Alliance (GISD)

Responsible
finance

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)

Institut de la Finance Durable(IFD, the Paris Institute for
Sustainable Finance, formerly
Finance for Tomorrow) is
an initiative led by Paris
EUROPLACE and aims topromote sustainable finance inFrance and internationally.

– Founding member

The Global Investors for
Sustainable Development(GISD) Alliance is seeks todeliver concrete solutions toscale-up long-term financeand investment in sustainable
development.

– The UN Secretary General
Guterres invited Valerie Baudson
to be part of the initiative

GISD’s work is supported bya Strategy Group appointed
by the CEOs and by United
Nations system partners
coordinated by UN DESA.

– 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; Participationin Building & Construction
Working Group) – Member of thebiodiversity working group as
well.

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High-Level Expert Groupon Scaling up Sustainable
Finance in Low andMiddle-income countries

October 2023

Responsible
finance

The primary tasks of theEuropean Commission’s
High-Level Expert Group on
Scaling up Sustainable Financein Low and Middle-income
countries will be to identify thechallenges and opportunities ofsustainable finance in low- andmiddle-income countries andto provide recommendations
to the European Commission.
The report will focus on how toincrease resources from private
capital to close the current SDG
financing gap and to accelerate
private financial flows for the
implementation of the external
dimension of the Green Dealand a green, just and resilient
recovery in our partnercountries.

– Elodie Laugel, Chief Responsible
Investment Officer, part of themember group

Further industry organisations in which Amundi is involved
Initiative

Topic

PurposeAmundi's involvement

Principles for Responsible
Investment (PRI)

Responsible
Finance

The PRI is the world's leading
proponent of responsible
investment and it works tounderstand the investment
implications of environmental,social and governance factors
and to support its international
network of investor signatories
in incorporating these factors
into their investment andownership decisions.

Amundi is a PRI signatory since2006 and as a consequence hasaccess to tools and resources. It iscommitted to the 6 PRI principles
and involved in PRI events (suchas the yearly PRI in Person event)and PRI transparency reporting anddiscussions/dialogue.

GIIN Operating Principles
for Impact Management

Impactinvesting

The OPIM Principles bringgreater transparency, credibility,and discipline to the impact
investing market.

Amundi has adopted the Operating
Principles for Impact Management- a market standard for impact
investing in which investors seek
to generate positive impact forsociety alongside financial returns
in a disciplined and transparent
way. Amundi publishes an annual
Disclosure Statement.

World Benchmarking
Alliance (WBA)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)

Institutional Investors
Group on Climate Change(IIGCC)ClimatechangeThe IIGCC mobilizes capital forthe low carbon transition and toensure resilience to the impacts
of a changing climate.

Amundi is a board member of theinitiative

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Banks'
transition to
net zero

The IIGCC and TPI publishedin July 2022 "An investor-led
framework of pilot indicators toassess banks on the transition
to net zero". The report gives
an indication of how 27 of thelargest global banks score on
their progress to transition
to net zero. The IIGCC Banks
Working Group supported theestablishment of the reportthrough engagement meetings/ emails.

Member of the IIGCC Banks Working
Group, lead on 2 banks (Bank of
China, Agricultural Bank of China)& co-lead on 2 banks (China
Construction Bank, ICBC)

ClimatechangeLaunched 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

One Planet Sovereign
Wealth Fund AssetManager Initiative

ClimatechangeEngage a community ofinvestors in our principles
to improve the impact anddistribution of international
capital and thus contribute toa gradual energy transition,
gradually leading to a moresustainable and less polluting
economy.

Pursued active membership

The Japan TCFD
Consortium

ClimatechangeCreated in May 2019 under
the auspices of the Japanese
Ministries of the Economy andthe Environment (Amundi
being the only non-Japanese
member of that consortium)and focused on improving
issuers' reporting on
environmental issues.

Attended regular meetings (onaverage every two months), as oneof the two representatives from theasset management industry.

Asia Investor Group On
Climate Change (AIGCC)

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 (lead & colead on 2 companies)

Powering Past Coal
Alliance (PPCA)

ClimateChangeThe Powering Past Coal Alliance(PPCA) is a coalition of nationaland sub-national governments,
businesses and organisations
working to advance thetransition from unabated coal
power generation to clean
energy.

Amundi has a thermal coal exclusion
policy aligned with the objectives
setup in the alliance included within
its responsible investment policy,
which is updated annually

Climate Action 100+

Lead on company engagement
on different sectors (Construction
materials; Airlines)

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FAIRR

October 2023

Environment& workingcondition

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

– Lead on specific companies’
engagements– Contribution to working group in
FAIRR’s Sustainable Proteins– Engagement in which 25 global
food manufacturers are asked
to disclose information on theirintention and long-term approach
to transitioning proteins portfolios
towards lower impact and moresustainable sources in line withthe 1.5°C world

Finance for Biodiversity
PledgeBiodiversity

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 memberof the initiative and participate
in its three working groups(Engagement with companies;
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

Net Zero Asset Managers(NZAM) initiative

ClimatechangeInternational group of asset
managers committed tosupporting the goal of net
zero carbon emissions by
2050 or sooner, in line with
global efforts to limit warming
to 1.5 degrees Celsius, and tosupporting investing alignedwith net zero emissions by
2050.

Amundi is a member of the NZAM
initiative and has committed tosupporting the goal of net zerocarbon emissions by 2050.

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 the engagementof a pharmaceutical company

Workforce Disclosure
Initiative Letter (WDI)

SocialdisclosureThis 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.

– Amundi drafts and sends lettersto companies complete the WDI
surveyThe 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, Retail & Food retail,A collaboration between thebio Initiative, the Access to
Medicine Foundation, thePrinciples for Responsible
Investment, and the UK
Government to galvanize
investor efforts to address
global antimicrobial resistance.

Active engagement with companies
and data providers

Platform for Living Wage
Financials (PLWF)

Investor Action on AMR
initiative

Living Wage

Antimicrobial
resistance– Member of advisory committee
in 2021

Active engagement (lead or co-leadon 11 companies),

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The 30% Club Investor
Group

October 2023

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 of the Frenchgroup, member of the Japanesegroup– Co-chair for 2021 engagement
season of the French group
Active engagement with companies(lead or co-lead on 3 companies)

Tobacco-Free Finance
PledgeHealth,human rights,
environment

Highlights the leadership ofmade institutions that have
implemented tobacco freefinance policies and encourageothers to follow.

Amundi has a tobacco exclusion
policy aligned with the objectives
setup in the pledge included within
its responsible investment policy,
which is updated annually

3. Illustrations of collective actions in which Amundi
has been involved
a. Collaboration with regulators
ICMA21 - Green, Social, and SustainabilityLinked Bonds Principles
Amundi has been an Executive Committee
member since 2017 and consequently plays anactive role addressing matters relating to the
Principles e.g. the development of Green, Socialand Sustainability-linked Bonds market and thestandardisation and impact reporting practices.
In 2022, Amundi was involved in the following
working groups: Impact Reporting, Climate
Transition Finance, Sustainability-Linked Bonds
and Social Bonds. Amundi was also a memberof other task forces on Secured Sustainable
Bonds and Sustainable Commercial Papers.

b. Collaborative work promoting best practice
Amundi frequently collaborates with industry associations, think tanks and NGOs on specific topics
in order to promote best practice.

➜ Our progress in 2022
The ASCOR Project
The ASCOR (Assessing Sovereigns’ Climate-related Opportunities and Risks) project is acoalition of international institutional investors22 as well as investor networks (UN Net Zero
Asset Owner Alliance, PRI) aimed at creating a framework and database to assess the climate
action and Paris Agreement alignment of sovereign issuers (both developed and emerging
markets). The projects academic research partner is the TPI Global Climate Transition Centre
based at the London School of Economics’ Grantham Research Institute.
Amundi is involved in the ASCOR project through funding and active participation in the working
groups. Investors willing to assess sovereign issuers’ climate-related risks and opportunities
currently face two main hurdles:
21. The International Capital Market Association
22. (including BT Pensions Scheme, the Church of England Pensions Board, Aktia Bank, Allspring Global Investments, AM,
Ceres, Colchester Global Investors, Franklin Templeton, the IIGCC, MFS IM, Ninety One, SURA AM

119 Stewardship Report 2022

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1. There is no internationally agreed climate-related framework dedicated to sovereign debt
instruments.
2. While a lot of sovereign data is publicly available, it is often not harmonised, comparable oreven consistent, which makes it difficult to conduct an appropriate analysis.
This lack of reliable tools hampers investors’ ability to undertake material analysis and toengage with governments on climate change, and subsequently undermines the climate
related investment case.
The aim of the ASCOR project is “for every sovereign debt issuing country to eventually beassessed against a framework which will analyse emissions pathways performance, policy
action, and opportunities to finance the transition. The framework will also focus on fairness,
recognising the principle of common but differentiated responsibilities that underpins theUnited Framework Convention on Climate Change.”
Such a framework should facilitate dialogue between private investors and sovereign issuersand help prioritise issuer engagement efforts to support increased climate ambition. It will also
support investors in achieving their net-zero commitments.
The project is currently in its testing and consultation/feedback phase and should be launchedin late 2023.
Combatting forced and child labour
Respect for fundamental human rights underpins social stability and enables the pursuit ofother social objectives including the promotion of equal and fair opportunities for all. We
expect companies to implement robust human rights policies and practices not only in theirown direct operations but also throughout their supply chains. With forced labour estimateson the rise globally23, we started a dedicated campaign on the matter and joined a collective
effort by the French Sustainable Investment Forum (FIR) and Human Rights Without Borders(RHSF) to develop a methodology for engaging with companies on the prevention of forced
and child labour.
We are participating with other investors on the Lab 8.7 Program - led by Ressources Humaines
Sans Frontières (RHSF) / Human Rights Without Borders - within the French SIF for an eightmonth period. The aim of this engagement called “experiment” by RHSF is to design and try
an alternative method for evaluating companies on the prevention of child labour and forced
labour risks in their supply chain. This alternative assessment of companies is based on thereference framework - dedicated to the prevention of forced labour and child labour – built up
by RHSF.
It is intended, among other objectives, to be actionable and appropriable by institutional andprivate investors and to support investors' decisions to contribute to the sustainable reductionof vulnerability to child and forced labour in supply chains.
RHSF is an NGO with 15 years’ experience in the field of forced and child labor. The RHSF teamhas been experimenting with pilot prevention solutions in partnership with stakeholders invarious parts of the world and shares its expertise with all those (companies, investors, tradeunions etc.) working for decent work throughout the supply chain.
In 2022, we progressed on the methodology with the RHSF. We hope to combine our efforts
to implement the methodology more broadly within our forced labour engagements in 2023.

23. https://reliefweb.int/report/world/global-estimates-modern-slavery-forced-labour-and-forced-marriageseptember-2022

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c. Collaborative work on Climate
Case study 20: Amundi's action with Climate Action 100+Amundi is an active member of Climate Action 100+ (CA100+), an investor-led initiative toensure the world's largest corporate greenhouse gas emitters take necessary action on climatechange. In 2022, Amundi supported CA100+ in a collaborative engagement with 15 corporates
from various sectors and regions. Amundi was lead for two of them and a collaborator on theothers.
Context: Since 2020, Amundi has been an investor lead within the initiative for a cement
and aggregates company based and operating in the United States. This company has been
identified as a climate laggard in the CA100+ Net Zero Company Benchmark as they lackcritical climate-related information, such as Scope 3 emissions. The company discloses carbon
emissions reduction targets that cover only part of its activities and material scopes. Thesetargets present poor climate ambition that is not aligned with the Paris Agreement
Amundi Actions: Amundi initially struggled to get a meeting with the company but finallyobtained one in 2021.
Based on our initial engagement the key objectives set were:– Strengthen climate-related disclosure,– Establish additional climate reduction targets on all material scopes and activities, and– Seek external certification for targets such as by the SBTi (Science-Based Targets initiative)
Over the course of 2021, we saw a lack of progress on our engagement objectives. The company
notably questioned the comparison with cement producers, due to limited revenue generated
by cement, as opposed to aggregates. Nevertheless, the production of cement is responsible
for the majority of their carbon emissions. Given the lack of expressed interest in acceleratingclimate topics, as well as the company’s rating in the CA100+ Net Zero Company Benchmark,we triggered an escalation by voting down all but one item at the company’s 2022 AGM.
During our 2022 discussion with the company’s representatives, we reiterated our requests
and expressed our concerns about the company’s lack of progress.
Our Updated Objectives for the company in 2022 were:– Raise the ambition of interim targets related to the direct greenhouse has GHG intensity of
cement production in order to align with the Paris Agreement,– Seek external validation of targets, such as by the SBTi,– Include Scope 1 in the net zero commitment, the most important scope in the company’s
carbon footprint,– Report on the main physical indicators that are driving the company’s GHG emissions,– Set quantitative targets on the main mitigation levers and disclose the planned contribution
to the achievement of emissions reduction targets,– Disclose the alignment of the company’s annual and planned capital expenditures, and– Prohibit the use of offsets to achieve the Scope 2 interim target.
In 2022, we sent a letter to the board of directors detailing the above expectations. We informed
the company that Amundi was considering several escalation methods if elements of the letter
remain unanswered.

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Engagement Outcomes and Issuer Momentum: Unfortunately, several elements we consider
critical remain unaddressed and we have not received a reply from the company in response
to our letter to the board of directors. Further, the company’s performance is still far below
industry peers. Despite this, we have observed the following positive developments in 2022.
– Reporting of direct lobbying activities in the next report, and– Inclusion of scope 1 in the net zero commitment in the next report.
Next Steps: We welcome the developments announced by the company. However, issues
mentioned above on the company’s climate disclosure and ambition – that we consider critical– remain unaddressed. We plan to keep pushing for those much-needed additional efforts thatwould better align the company’s strategy with investor interests. Amundi has filled a climaterelated shareholder proposal for the company’s 2023 Annual General Meeting.

Case study 21: Amundi co-leads engagements with Chinese banks with the IIGCC
Amundi is co-leading a collective engagement campaign that focuses on Chinese banks
through the Institutional Investors Group on Climate Change (IIGCC).
IIGCC is a group of asset owners and asset managers with about €60 trn under management.
The objective of the IIGCC initiative “IIGCC Net Zero Investor expectations of Banks” is thedevelopment of a net zero assessment framework for the banking sector, in collaboration with
the Transition Pathway Initiative. This framework is to provide guidance on banks’ alignment
with a 1.5°C pathway.
As part of this project, Amundi is co-leading engagement with Chinese banks. The aim is toimprove the transparency of disclosure and communication to investors by Chinese banks ontheir coal phase out policies, net zero commitments and governance. Amundi, in its role asco-lead engager, will continue to push for engagement with more Chinese banks, given thesignificant role they can play in the energy transition. As some of the world’s largest banks,
they have the capacity to fund sustainable energy projects and to accelerate the phase out offossil fuel energy.
Context
Banks have a role to play in climate change, alongside governments and the private sector,
to encourage carbon-intensive borrowers to phase out activities that produce large amountsof emissions and help them transition to low carbon processes or products. They can also
direct funding to more sustainable and low carbon solutions. Chinese banks, in particular, areimportant players in the global energy transition given their size and the fact that China’s
economy is still highly dependent on coal. This is the main reason for our engagement with amajor Chinese bank, many also have significant room to improve on management and board
diversity standards. The primary topic for our engagements with Chinese banks in general,
however, concerns environmental factors.
Amundi Actions
Amundi has engaged with this major Chinese bank for two years. The engagements focusedon its net zero transition pathway, with a specific request for the bank to improve its transition
practices by developing definitive KPIs. In November 2022, we engaged with the bank as alead in the Institutional Investors Group on Climate Change (IIGCC) collaborative engagement,alongside other investors.

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Key Objectives for our engagement were to encourage the bank to publicly announce its fossil
fuel policy and to commit to phase out coal. We also took the opportunity to encourage thebank to increase its board diversity, with a particular target of 30% female board members.
Engagement Outcomes and Issuer Momentum– The bank now has a strict fossil fuels policy and is promoting the transition to a low carbon
environment as demonstrated by its falling exposure to the fossil fuel industry, in particularcoal. In line with the Chinese government proclamation the bank is no longer funding coalprojects outside China, however has no such domestic policy. The bank’s ESG strategy
mirrors that of the Chinese State, which will likely constrain any progress.
– The bank committed to disclose its board gender diversity targets in the near future.
Next Steps
Given the important role China has to play in the energy transition, Amundi will continue to ask
the bank for more transparency on its fossil fuel policy and to align their policy with the Paris
Agreement timeline. In that respect, our main request remains for the bank to commit to a coalphase out, ideally according to a 2030/2040 timeline.
We will also follow up with the company on its promised disclosure of targets on gender board
diversity. We will reiterate our long-term demand for the bank to meet the 30% female director
ratio.

d. Collaborative work on Natural Capital preservation
Case study 22: Collectively Engaging on Fishing & Aquaculture with FAIRR
In July 2019, Amundi became a signatory of the Farm Animal Investment Risk and Return
initiative (FAIRR24). The innovative peer network for institutional investors seeks to use theirinfluence to help global livestock, fish and dairy companies change their behaviour and build amore sustainable global food system.
In the past couple of years, FAIRR launched a collective engagement campaign called
Sustainable Agriculture. It is targeting eight salmon companies and encouraging them todiversify their feed ingredients and reduce dependency on feed sources such as soy, fishmeal
and fish oil (FMFO). Reducing such dependency is an important part of lowering climate
impacts, mitigating biodiversity risks, and promoting sustainability and long-term resilience inthe aquaculture sector, which complements our thematic engagement workstream on oceans.
Amundi Actions: In 2022, we collaborated with other investors and jointly-led an engagement
call with one of the targeted companies. The engagement was divided into sub topics witheach investor taking lead on one subtopic. The aim of the engagement call was to press formore disclosure on aspects of the company’s feed strategy.

24. https://www.fairr.org/

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Key Objectives for our engagement were:– Publicly disclose absolute volumes of FMFO sourced through feed, the breakdown of FMFO
sourced from whole fish and by-products and R&D spend and projects related to novel feed
ingredients, including work on blue mussels and sugar kelp,– Greater public discussion and disclosure of how the company’s current investments and useof alternative feed ingredients are expected to replace FMFO usage,– Conduct and disclose a forward-looking risk assessment examining how marine and soy
ingredient sources could constrain production and increase exposure to ESG risks, including
climate risk,– Disclose strategies to increase the use of trimmings and processing waste, as informed by
the risk assessment,– Disclose strategies to increase the use of alternative feed ingredients (e.g., algae, insects,
single-cell proteins, high omega-3 oilseeds), as informed by the risk assessment, and– Disclose a target to increase the use of alternative feed ingredients, as informed by the risk
assessment.
Engagement Outcomes and Issuer Momentum: The company now discloses levels of FMFO,
and has even disclosed reasons for the increase in FMFO use since the last reporting year. The
company detailed the ongoing novel feed project at the company, and explained some of the
key limiting factors to increasing the novel feed ingredients at present. These reasons included
the carbon footprint of alternative ingredients; the company aims to reduce its emissions by
46% by 2030, of which 43% comes from feed production. The company also shared issues withthe lack of availability and price associated with novel feed ingredients.
Next Steps: We appreciate the developments that we have seen at the company, and lookforward to working with FAIRR to follow up with the company in 2023. Our requests will
include a high level risk assessment on the company’s continued reliance on FMFO. Other
things we hope to see from the company in future include targets on novel feed ingredients,
and details of fully worked forage fish dependency ratio (FFDR) calculations.

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e. Collaborative work on working conditions, living wage & gender
diversity
Case study 23: Collaborative Engagement with US Food Processing Company
through FAIRR
Context: One of FAIRR’s major engagement campaigns is on Working Conditions across theglobal agricultural sector. The industry has a heavy reliance on human capital meaning thatlabour practices are an extremely relevant consideration. FAIRR’s campaign seeks to address arange of labour-related issues including the adoption of automation to improve worker safety
and food security, compliant with international labour standards, and the enforcement of thesepolicies.
Given our ongoing work on wages, labour conditions and human rights, FAIRR’s collective
engagement campaign aligns well with our broader thematic focuses in this area.
Amundi Actions: In 2022, we collaborated with other investors to jointly lead an engagementwith an American food processing company to ensure that the company has the right policy
structure and enforcement mechanisms in place to empower workers, regardless of contract
type or geography. Amundi led a specific portion of the engagement call.
Key Objectives for our engagement were:– Better disclosure on grievances reported, disaggregated by category,– Disclosure of the distribution of workers across employment contract types for all
operating markets,– Get clear information on the company approach to worker representation at the board
level, and– The company’s strategy should assess the impact of climate change and automation on theworkforce to supporting a Just Transition in meat production.
Engagement Outcomes and Issuer Momentum: We noted some positive developments atthe company during 2022, including the launch of an automation programme to de-risk some
jobs and an update to the ethics hotline at the company to become completely anonymous,
available in multiple languages and available 24/7. Alongside this, the company launched acampaign to advocate use of the ethics hotline and for individuals to speak up when theyobserve concerning behaviours.
However, since then, the company has faced serious allegations of forced and child labourand poor working conditions at a number of facilities. With this in mind, we will be monitoring
developments at the company extremely closely.
Next Steps: As part of the collaborative engagement campaign, we will be looking to follow
up again in 2023. In particular, we will be looking for more information on the company’s
assessment of the social impact of automation and climate change on their specific workforce
and other stakeholders. This will be an important piece of analysis in conjunction with our own
thematic campaign on a Just Transition. Amundi will also be pushing to get more disclosure
from the company on employee metrics by contract type, and reported grievances by category.

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Case study 24: Living Wage in Supply Chains: PLWF Collaborative Engagement
Platform Living Wage Financial (PLWF) is a coalition of 19 financial institutions representing
a total of €6.5 trillion of AUM that engage and encourage investee companies to enable living
wages and incomes in their global supply chains. PLWF focuses on living wages for contracted
workers in the garment and footwear sector, and for retail companies’ own employees. Selfemployed workers, such as cocoa and coffee farmers, are not paid a wage but earn an income
from one or multiple income generating activities.
As recognised by, among others, the International Labour Organisation (ILO) and OECD, living
wage is a fundamental human right and is instrumental in the battle against poverty. Sectorsthat strongly depend on manual labour; such as garment, agriculture, food and retail workers,
pay wages that are often insufficient to cover basic living expenses. Wages in these sectors
are often on or below the poverty line, even if there is a legal minimum wage, and well-below
national living wage estimates.
Amundi Actions
Engagement Selection
Amundi joined PLWF in 2018 and has continued to play a key role in its annual engagement
activities.
Engagement Objectives
Companies are scored using the PLWF developed methodology25 that was created inconsultation with industry experts and an independent accountancy firm, and which is alignedwith the UN Guiding Principles. Based on their scores, companies are categorised as embryonic,
developing, maturing, advanced, and leading. This is done to:
1. Encourage companies to address the non-payment of living wages in global supply chainsthrough policies, data, targets, and timelines for living wage adoption, and
2. Improve company adoption of internal best practices that support living wages; including
reporting, grievance mechanisms, promotion of freedom of association and collective
bargaining and purchasing practices.
Amundi Activities
Amundi is actively involved in the Garment & Footwear, Food & Agriculture, and Food
Retail working groups. In 2022 Amundi was lead engager with four companies in Garment& Footwear, and two for Retail, as well as co-lead for many others. The full list of companies
under engagement can be viewed on the PLWF website.
In addition to the annual assessment and engagement campaign, Amundi has joined forces
with other investors to actively engage on wage-linked controversies identified by the investor
group to put collective pressure on companies under engagement to fully and effectively
address areas of concern.
Amundi has now participated in four assessment and engagement cycles with the PLWF.
Outside of the collective effort of the investor group, Amundi has used the PLWF’s assessment
results to empower its voting decisions26. Companies which continue to demonstrate poor or
no momentum on the topic have been subject to votes against the discharge of some board
members.

25. PLWF methodologies are sector specific and open source and can be viewed on the PLWF Website
26. Voting decisions are done based on Amundi’s own Voting Policy and engagement strategies strictly independent fromother investor members in the PLWF – more details can be found in Principle 12

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Engagement Outcomes & Issuer Momentum: While a full review of the PLWF’s annual efforts
can be viewed in the Annual Report, the key findings for the sectors is as follows:
Garment and Footwear– Policy commitments and operational understanding of living wages are becoming morerobust– Evidence on the impact of multi-stakeholder collaborations is limited 25% of brands fail topromote– Freedom of Association in supply chains– Urgent need for impact assessments and wage gap analysis– Positive momentum towards the integration of assessment findings– Companies have lost ground on effectiveness measures
Agricultural & Food
– Recognition of living income in formal policies must advance– Well-informed action towards supply chain wide targets is needed Feedback fromstakeholders is not integrated in processes– Weak complaint and remediation mechanisms for human rights grievances
Retail– Income considerations for a company’s own employees are increasingly in scope– Companies often lack a clear strategy or KPIs on living wage.
– Lack of integration of a living wage/income in purchasing practices– Weak complaint and remediation mechanisms for human rights grievances
Next Steps and Amundi Perspective of Engagement: Based on the PLWF’s results, it is clearthat companies are far from effectively addressing the non-payment of living wages in global
supply chains. There has been limited progress on this topic in the aftermath of the COVID-19
crisis and global struggles with inflation have exacerbated the need for living wage.

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Case study 25: 30% Club, Société Générale
Context: Based on recent data, 31% of companies in the SBF120 in France have at least 30%
of women in their executive committees (compared to 18% in 2020) but only 9% have at least
40% (up from 6% in 2020)27. The financial sector shows a very good gender balance in termsof the percentage of women in the total workforce, with averages being around 50%. While we
could expect a similar proportion of representation at the senior executive management level,
this is not the case. This represents a lost opportunity for financial companies, which have hadaccess for a long time to a large female talent pool28.

Public data on gender diversity at senior executive management level of a sample
of French financials
Company% of women in workforce (2022)% of women in ExCom (2022)*

Societe Generale

54.0%

20.0%

Company A

52,5%

40.0%

Company B

52.0%

0.0%

Company C

54.3%

21.4%

Company D

48.0%

25.0%

*Defined as management level below board, companies have different names for the executive committee, e.g.
General Management or Management Committee.

At the time the 30% Club France investor group was launched in late 202029, Société Générale(SG) had 57% women in its workforce, but only 16% of its General Management members were
women.
Amundi Actions: We first met with SG in January 2021 with the Chairman, as part of Amundi’s
involvement with the 30% Club France (Amundi was the investor lead).
At the start of the engagement in 2021, the investor group’s specific objectives for SG were as
follows:– Demonstrate a greater gender balance at the General Management level (highest governing
body below the board) with more concrete momentum towards SG’s targets andcommunicate on a near term action plan.
– Publicly disclose a clear action plan on how SG intends to drive gender diversity at thecompany all the way up to the highest management levels
Diversity and inclusion is a strategic priority for SG; the company has a target to have at least
30% women on its management bodies by 2023. SG’s year end performance towards thistarget was as follows:– Strategic Committee (Top 30 positions), 23% women at the end of 2021
– Management Committee (Top 60), 26% women at the end of 2021
– Key group positions (Top 150), 25% women at the end of 2021

27. https://30percentclub.org/wp-content/uploads/2023/01/30CLUB_FR_2022-Annual-Report-1.pdf
28.https://30percentclub.org/wp-content/uploads/2022/01/30Club_France_Diversity_Report_Final.pdf
29. https://30percentclub.org/france-investor-group/128 Stewardship Report 2022

October 2023

Engagement Outcomes and Issuer Momentum
In 2022, we observed key positive developments at the company. First, with the nominationof a female as Deputy General Manager and Chief Operating Officer in January 2022, theproportion of women in General Management increased to 33% (2 out of 6). This is despite SG
not having a target at the General Management Level. However, we note that SG announced in
October 2022 that this person will leave the bank effective 31 December 2022. Depending on
her replacement, the percentage of women on the General Management may evolve in 202330
Building upon the progress observed, Amundi led a follow-up meeting with SG later in 2022with the 30% Club France Investor Group. Based on this call, we noted additional positive
developments. SG informed us that as of 2022 they aim to have at least 50% women on
succession plan slates compared to historically including at least 1 female. SG was also open
to our feedback on additional disclosure for more granular diversity data, we provided SGwith the 30% Club France Investor Group’s KPI list to provide guidance on the investor group’sreporting expectations.
Based on the company’s developments and our 2022 engagement dialogue we evolved our
engagement objectives for the company.
Updated 2022 engagement were as follows:– Encourage increased transparency around the measures SG has in place for retention of
female talent once promoted, given the trends seen in the 2021 data. We noticed there wasa drop in percentage of women on the Management Committee (top 60) to 26% in 202131
from 29% in 2020
– Encourage SG to disclose more granular diversity data to allow investors to assess SG’s
progress, such as gender breakdown of turnover rates and percentage of women in the
top-10 remuneration of the company– Encourage SG to become more ambitious than its current target ‘at least 30% of women by2023 in management bodies’, given the proportion of women in its workforce
Next Steps: Going forward in 2023, Amundi will continue to engage with SG to follow up
on the actions the bank is taking to achieve its targets as well as how SG are assessing theeffectiveness of those strategies. Given that gender diversity and inclusion is an import topic
for SG, we plan to continue engaging with the bank so that they can become a best in classexample for the sector. We will also monitor for any potential change in strategy on thisimportant topic under the new CEO who takes up his role in May 2023.

30. We note that on 9th March 2023, a new executive governance structure that will be effective from 23rd May 2023. There
will be a core General Management team (CEO and two Deputy CEOs) and this core team will be part of a wider new
Executive Committee. In this Executive Committee at the date of formation, of the 13 members 7 will be women.
31. At the end of 2022 this ratio was 27%

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d. Support for research into responsible investment matters
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.

• Amundi has renewed its partnership with
EDHEC-Risk Climate Impact Institute. Amundi
has been a partner of EDHEC-Risk since 2009,
and through time EDHEC-Risk has become thepremier academic centre for industry-related
financial research on risk and investment
management, especially on ETF. In October
2022, the institute changed its focus and thus its
name to EDHEC-Risk Climate Impact Institute(EDHEC-Risk Climate), reinforcing EDHEC’s
commitment to helping organisations integratesustainability risk and impact considerations.
Amundi sponsors the new research chair on“Measuring and Managing Climate Risks in
Investment Portfolios”. EDHEC-Risk Climate
aims to become a leading academic reference
point helping long-term investors manage theasset-pricing implications of climate change
as well as mitigation and adaptation efforts.

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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 change and the way we
decide to engage will always be based on its expected effectiveness. When engagement fails orif the remediation plan of the issuers appears weak, we may enact a mode of escalation up to thepoint 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 organisations
can prove to be complicated, disruptive andeven considered by issuers to be impossible.
This is why we seek consensus and action onreasonable milestones during engagementmonitoring while not settling for progress
merely for the sake of progress. As investors wemust temper our 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 can 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) – see Principle 7 for moredetails of Amundi’s proprietary ESG scoring
system,– and ultimately exclusion.

For example, in the case of themes that are critical(such as climate, natural capital preservation,social matters, severe controversies and/ or
violations of Global Compact principles) or
where there has been a 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.In
addition to exercising escalation through ourvoting activities, failed engagement can havea direct impact on our ability to invest in acompany. ESG Research analysts can downgrade
the related criteria in the ESG score of the issuer,and in the case of a critical issue, the overall ESG
score can be downgraded.

131 Stewardship Report 2022

Amundi has committed to integrate ESG criteria
into the investment process of actively managed
open-ended funds, with an objective to fulfil
the financial objectives while maintaining theportfolio average ESG scores above the averagefor their respective investment universe.
Negatively overriding ESG scores therefore
creates a penalty in our capacity to invest in the

October 2023

issuer. Occasionally, an issuer's ESG rating canchange from being investable to excluded due
to its obstinacy on an ESG issue that we believe
to be crucial.
The ultimate form of escalation is exclusion, incase of failure to engage and remediate on a
critical issue.

a. Responding to controversies leading to divestment
Case study 26: Escalation following a controversy at a European food company
Context: During spring 2022, a European food company faced a major controversy regarding
their product safety. French authorities confirmed a link between dozens of E. coli infections
in children and frozen pizzas sold by this company. In total, 75 infections have been reported,
including 53 confirmed cases of haemolytic uremic syndrome (HUS), with another 26 cases
still under investigation. Sick children were aged from one to 18 with a median of seven years
old. Two have died.
Amundi’s action: We promptly engage the company on the subject. The company was
reluctant to discuss the matter during our engagement as they did not wish to comment on
the situation due to ongoing legal proceedings. Nevertheless, they had no plan going forward
to have top level remuneration linked to quality assurance, neither had they any reaction about
the weaknesses in their audit system that led to this controversy.
Two criteria of the ESG score - community involvement and product safety – of the issuer werethen overridden leading to a downgrade of the final score.

Case study 27: Responding to emerging controversies at a European chain ofnursing homes
Context: The issuer, a French and European leader in the private for-profit nursing home sector,
faces a lot of controversy regarding unethical behaviour, toxic culture and governance issues.
Detailed investigations revealed issues like fraudulent work contracts, embezzlement of publicfunds, potential conflicts of interest with the Ministry of Health and tax evasion. These issues
have limited the group’s ability to provide adequate staffing and medical care, and accusationsof a management style based on “terror” have further exacerbated the situation.
Amundi Actions: We have actively monitored and engaged with the company over the
past decade, due to persistent issues that seemed more pronounced than for their industry
competitors. The emergence of new allegations highlighted a system rooted in social
malpractices and misappropriation of public funds, prompting an urgent reassessment. Viewing
these as a breach of the UN Global Compact, Amundi's ESG rating committee held a special
session in the week following the new revelations.
Key Objectives: Amundi’s key objectives were to reevaluate the issuer based on the new
information, assess their adherence to the UN Global Compact and determine the potential
impact on their ESG score.
Outcomes & Next Steps: In response to the evaluation and the analysis from the ESG analyst
covering the issuer, the committee made the decision to exclude the issuer from Amundi’s
active investment universe. This exclusion reinforces Amundi’s stance against unethical businesspractices and emphasises the importance of ESG considerations in its investment decisions.

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b. Escalation by voting against the discharge or renewal of boards
members
Case study 28: AIG
Context: Amundi has been actively engaging in dialogue with insurance companies on theircoal exit strategy, as we believe a shift towards best practices in this sector’s policies cansignificantly contribute to the energy transition. American International Group (AIG), one of
the largest insurance companies, had committed to reach Net Zero by 2050, but still had nopolicy regarding the underwriting of coal-related projects. Amundi has been engaging with theCompany regarding its coal policy since 2020, but AIG’s answers were not deemed sufficientto address our concerns.
Amundi’s action: For that reason, Amundi decided to hold the Audit Committee accountable
and to vote against the re-election of the Chair of the Audit Committee at the insurancecompany’s 2022 AGM (99% support).

Case study 29: Martin Marietta Materials
Context: Since 2020 and supported by other investor members of the CA 100+ coalition,
Amundi has led a collaborative engagement with Martin Marietta Materials, a cement andaggregates company based and operating in the United States. The Company has been
identified as a climate laggard in the CA 100+ Net Zero Company Benchmark. It has failed
to release critical climate-related information that is disclosed by peers producing cement. It
discloses carbon emissions reduction targets that cover only part of its activities and material
scopes. The Company presents limited climate ambitions overall, which Amundi considers
unaligned with the Paris Agreement.
Amundi’s action: Despite our engagements with the Company, multiple critical elements of its
climate strategy were still considered inadequate. Amundi opposed the re-election of all Board
members at the 2022 AGM (support level was 95% or higher).

Illustration 20: Escalation by raising a question at an AGM - Credit Suisse
Context: We continued our ongoing discussion with Credit Suisse on the bank’s energy policy
and climate strategy during 2022. Our engagement with the Swiss bank has spanned acrossseveral years now. Even though considerable progress has been made over this period, Credit
Suisse’ climate policy remains insufficient, notably in terms of thermal coal exclusion andtransparency.
Amundi Actions
Our 2021 & 2022 engagement initiatives
At the 2022 AGM, Amundi filed a climate resolution together with 10 other institutional investors(managing a total €2.18trn of assets) and coordinated by ShareAction32. It was a milestone as
it was the first climate resolution to be voted at a Swiss company. The resolution turned out tobe a success; receiving 18.5% of support, 4.3% of abstain.
Subsequently, we had a collective follow up meeting – alongside ShareAction, the Ethos
Foundation and some of the other coalition investors – with Credit Suisse in December 2022.
The purpose of this meeting was to influence the contents of the Say on Climate plan, which
the bank will put to a vote at its 2023 AGM.
32. The co-filing group was made up of ShareAction and eleven institutional investors including the pension fund of
Zurich city, Pensionskasse Stadt Zürich; the Swiss Federal Pension Fund, Pensionskasse des Bundes PUBLICA; and Ethos
Foundation, composed of 235 Swiss pension funds and public utility foundations.

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Timeline of Engagement Actions for Credit Suisse and Corporate Evolution
Amundi actions

Amundi demands

Company actions

Aug.
2020

_

_

Strengthening of coal policy

Jan. 2021

Company meeting on ESG
issues– Inclusion of ESG performancetargets into variable
remuneration_– Set sectoral emission
reduction targets– Removal of exceptions on thecoal exclusion policy

Feb.
2021

_

_

Signing up to the SBTi

March
2021

Company meeting on climate
issues– Commitment to phase outcoal_– Removal of exceptions on thecoal exclusion policy– Extension of coal exclusion
policy to asset managementbusiness

April
2021

Company meeting oncontroversies_

Funding member of NZBA

2021
AGM

Joint investor statement– Commitment to phase outcoal_– Exclusion policy on coaldevelopers– Commitment to help clients
implement coal phase outplans– Publication of more
information on the expectedtransition strategies of clients– Vote AGAINST reelection
and reappointment ofseveral board members due
to a failure of their control
duties (Greensill, Archegos
controversies).

_

_

_

Publication of an updated coal
policy:– Commitment to phase out
coal– Vote AGAINST all
Remuneration items ex
ante and ex post linked toChairman and Executive
Members– Vote AGAINST dividend

Nov.
2021
(COP26)_– Exclusion policy on coaldevelopers– Commitment to tighten coal
revenue thresholds over time134 Stewardship Report 2022

March
2022

_

2022
AGM

Joint investor resolution

October 2023_

– Joined the NZAM initiative– Published emission reduction
target for the energy sector– Introduction of a climate
article in the banks’ Articles of
Association_– Improve climate risk
disclosures– Bring coal policies in line withleading sector practice– Vote AGAINST reelection
and reappointment ofseveral board members.

_

_

_

Publication of Climate Action
Plan for the asset management– Vote AGAINSTRemuneration items.
– Vote AGAINST dischargeof Board and Senior
Management for Fiscal Year
2020 and 2021.
– Vote AGAINST dividend– Vote FOR approval of a
special audit– Vote FOR our own investor
resolution

Dec.
2022

_

activities, including:– emission reduction targets– thermal coal exclusion policy

Dec.
2022

Joint investor company
meeting– Removal and/or clarificationof the exception on the groupcoal policy_– Extend the Asset Management
coal exclusion policy to the fullproduct range– Publication of emission
reduction targets for
additional sectors– Extend the scope of emission
reduction targets to also
include facilitated emissions– Provide further transparency
on the Client Energy Transition
Framework

Most recent engagement objectives
In the resolution presented at the 2022 AGM, the investor coalition asked for the introductionof a climate article (commitment to align with 1.5°C) in the bank’s Articles of Association33.
More specifically, the investor coalition asked the bank:– to improve its climate risk disclosures (including emission disclosures and targets to also
cover the capital market activities);– to bring its coal policies in line with leading practice in the sector (removal of the
exception34, application to the asset management activities).
33. shareholders are also asked for these disclosures and commitments to be made in the management report, as
opposed to the bank’s sustainability report, in line with TCFD guidance
34. “unless supporting energy transition”

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During the December 2022 meeting, the primary demands from the investor coalition were as
follows:– removal and/or clarification of the exception on the group coal policy;– extend the Asset Management coal exclusion policy to the full product range;– publication of emission reduction targets for additional sectors;– extend the scope of emission reduction targets to also include facilitated emissions (capital
markets facilitation and underwriting);– provide further transparency on the Client Energy Transition Framework, including timelines
and mechanisms to upgrade, downgrade or end relationships with clients.
Engagement Outcomes & Issuer Momentum 2022: Further to the achievements reached in
the last few years. The following positive outcomes were achieved in 2022:– Credit Suisse Asset Management joined the Net Zero Asset Managers initiative (NZAMI) in
March 2022.
– In December 2022, just ahead of our (collective) engagement meeting with Credit Suisse,
the bank published a Climate Action Plan for CS Asset Management and Credit Suisse
Wealth Management. This plan includes:- a commitment to half emission intensity of investments by 2030 for equites and corporatedebt- an exclusion policy on thermal coal
- tightened policies around oil & gas and oil sands.
Next Steps: We recognise that Credit Suisse has made progress in an environment thatwas particularly challenging for the bank. Remember that the bank has been implicated incontroversies affecting its reputation (Greensill, Archegos) and subsequently suffered fromhigh turnover among management and employees.
Still, there are several remaining topics that justify continued engagement with the bank. For
Amundi, the most important issues currently outstanding are:– So far, emission reduction targets have been set for only one sector (energy sector).35– The scope of disclosures and targets does not cover committed exposure (only drawn
exposure).
– The scope does not cover the capital markets activities36.
– Concerning the coal policy (which, as a positive point, does cover capital markets
activities):- It contains exceptions for companies “supporting the energy transition” without enoughtransparency on what this means.
- The coal policy of the asset management activities looks weaker:- It contains no exclusion of coal developers- It applies to a restricted product offering only
- The oil sands policy of the group looks weak37, while the policy of the asset management
activities only applies to a restricted product offering38.
In light of the merger with UBS, Amundi will assess how to follow up during 2023.
35. Since this report was written, but before its final publication, Credit Suisse announced emission reduction targets for 5
additional sectors.
36. Even though over 75% of its financing of top oil and gas expanders is in the form of capital markets financing
37. “No lending or capital market underwriting for companies deriving more than 25% of their revenues from oil sands
unless these companies have materially reduced their overall emissions intensity over time and have credible plans tomaterially reduce carbon intensity further.”
38. “Restriction on companies active in oil sands with a 10% revenue threshold. Expected to be effective as of April 1, 2023,
and will apply to actively managed portfolios classified as “2 – Avoid harm” and above within CS AM and to all singlesecurity investments within discretionary mandates and wealth funds managed by CS Wealth Management”

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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. How we exercise voting rights______________
a. Our approach
The Voting & Corporate Governance teamconsists of eight specialists who analyse
resolutions and organise ongoing dialogue withcompanies, pre and post AGMs, with the aim of:– Being a responsible investor through theexercise of the voting rights and following aclear voting policy that encourages strong
governance and accountability of boards andmanagement on environmental and social
issues,– Encouraging adoption of governance bestpractice through pre-and post AGM dialogue,either by highlighting key elements of ourvoting policy and, when possible, by alerting
the issuers when we intend to vote against 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, and– 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 our regular dialogue with issuers,
Amundi informs companies of our proprietary
methodology for ESG analysis and the rating
assigned to them; and we explain any changes
as they arise. The positions we express in ourvotes should not surprise companies. They are
the result of our analysis and dialogue, based on
fully transparent criteria. Amundi has centralised
the exercise of voting rights within the Voting &Corporate Governance team and exercises thevotes on behalf of its subsidiaries and funds.
We are committed to transparency and, where
possible, we inform issuers of planned negative
votes.
In 2022, as the Voting & Corporate Governanceteam grew in size following the acquisitionof Lyxor, Amundi continued to increase thenumber of active dialogues with issuers aroundAGM season.
The following entities have delegated voting
to the Voting & Corporate Governance team ofAmundi: Amundi Asset Management, Amundi
Austria, Amundi Canada, Amundi Deutschland,
Amundi Hong Kong, Amundi Japan, Amundi
Iberia Amundi Immobilier, Amundi Ireland,
Amundi Luxembourg, Amundi Sgr, Amundi
Singapore, Amundi UK Ltd. BFT IM, CPRAM,
Etoile Gestion, Sabadell Asset Management,
Société Générale Gestion.

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2. Amundi’s voting policy ___________________
Amundi intends to fully exercise our
responsibility as an investor by voting at general
meetings according to our voting policy.

– Climate accountability on board

Amundi has developed our voting policy
according to our 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 andpart of the custom analysis (analysis of theresolutions according to Amundi’s voting rules)
is performed by ISS, an external provider. This issupplemented by the analysis of three different
proxy advisers: ISS (general voting policy, Glass
Lewis, Proxinvest. The policy is reviewed on anannual basis and is available on our corporatewebsite.

– Material risk and opportunity assessment

The key elements of the voting policy include:
Shareholder rights: A corporate governanceregime must protect and facilitate the exerciseof shareholders’ rights and ensure fair treatmentof all shareholders, including minority andforeign 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.
For a board to be effective, a fair level of
independence and diversity is needed as well
as a limitation of over-boarding.
Amundi fully backs the eight principlesof the World Economic Forum’s Climate
Governance Initiative:– Command of the subject– Board structure– Strategic and organisational integration– Incentivisation– Reporting and disclosure– Exchange
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 approach to pay,
and more broadly its sharing of value overall,
do not generate unacceptable situations ofsocial inequality. Pronounced socioeconomic
inequalities are detrimental to GDP growth, andeven though inequalities have different grounds,
corporates have an impact on them.
Therefore, we have reinforced our dialogues
with companies concerning the critical need tofocus on the long term while balancing 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 stringent ESG performance criteria
in the variable remuneration, as well as KPIs
related to climate for issuers from the climate
high impact sectors.
Amundi assesses each environmentally orsocially related shareholder resolution.
Corporate governance analysts seek, whenneeded, the help of the ESG analysts to assess
the value of the proposal for the shareholders.

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a. Scope of the voting policy
The funds exercise their voting rights at equity
investee company meetings whenever possible.
Our voting approach applies to all Amundi
managed equity funds. Voting rights are
exercised for all shares held, unless the required
period during which trading is blocked or any
custodian risks is creating a potential adverse
impact on our clients as it would hinder portfolio
managers’ trading discretion. In some rare
instances we may not be able to ensure effective
voting for some or all of the shares held. In 2022,
we voted for 99% of the shares held.
When the management of an equity portfolio is
entrusted to an outside manager, that manager
may have the voting rights, as provided in thedelegation contract. Clients with segregatedmandates can require us to apply their own
voting policy. Voting rights are exercised for
securities held in the portfolio at the time of theGeneral Meeting. To fully exercise these rights,

the lent securities can be recalled in accordancewith local laws, technical constraints, and theinterest of the meeting. The decision to recall theshares will be based on a qualitative appraisal,
taking into account the nature of the proposal,
the size of Amundi’s voting power, and/or the
potential consequences of the vote. For the SRI
labelled funds, shares are systematically recalled
for all issuers several days before the meeting
record date in order to hold the rights to vote at
the meeting.
In 2022, we voted on all holdings where it
was economically viable to do so, which was
99% the total of the votable assets under the
responsibility of Amundi (meaning we voted on
more than 10,200 AGMs).
Full disclosure of all our latest voting decisions isavailable on our corporate website.

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) analyses thecompatibility of the proposals with the voting policy todetermine 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 inline the voting
policy can be
determined, thevote is instructed.

If the Team
identifies a
conflict ofinterest:
preparation ofan explanatory
file for the
VotingCommittee.

Access to internal
expertise,external expertise& customrecommendations
and 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 withintention 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, the committee includes Senior Managers from investment, financial and extrafinancial analysis, as well as external advisers.
The Committee determines Amundi voting policy and the voting rules.
* Reviewed on a yearly basis, voting rules are described in an application document (internal).

139 Stewardship Report 2022

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3. 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 being able to vote in proportion to theownership of the capital and not being facedwith limitation or protection mechanisms thatwould allow the company to circumvent thedecision-making power of its shareholders.
In 2022, Amundi funds exercised their voting
rights at company meetings in which they havean equity investment39 whenever possible40.
Our voting policy includes certain high-levelgovernance principles that are universally
applicable, such as independent oversightand alignment of agents’ remuneration with
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 according to our understanding of
the limit of what is possible each of these local
contexts and we seek to position our votes
accordingly.
Our decisions are always made with a view
to defending the interests of our clients bysupporting the creation of sustainable longterm value41. To do this, Amundi considers eachcompany’s context in a pragmatic manner tomake sure our voting decisions are effective;
especially, for example, regarding gender
diversity. In that case Amundi may link the votewith a specific engagement stream.
Amundi’s Voting & Corporate Governance teamclosely monitors the votes, working with proxyadvisers and custodians to understand thereasons why any vote could be rejected and to
implement corrective measures if necessary.

a. Voting against management as an escalation mode
In addition to the traditional AGM items on
which Amundi votes under our voting policy(as outlined in section 2 of this principle), we
have used votes to express concerns following
failed engagements or in case of failure to act
on topics representing systemic risks; such as
the energy transition, coal phase-out, and social
cohesion. Amundi voted against the dischargeof the board or management, and against the reelection 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
or environmental strategy,– A selection of companies with controversialsocial practices.

Progress towards 2023
Amundi expects companies to be responsive
to the concerns expressed by shareholders
through their votes and engagements. A lackof responsiveness by a company will impact ourvoting decisions as we believe it is critical tohold board members to account.
Starting in 2023, the Voting Team will launch
an annual engagement campaign to contact
the board or chairs of companies that received
more than 20% dissent, asking them to engage
with their shareholders and explain how thisdissent was taken into account. Depending on
the companies’ answers, Amundi may decideto vote against the renewals of directors at thefollowing general meeting.

39. 99% of the shares held of portfolios of our voting universe. Ballots’ failures are explained by operational problems
40. See appendix of the voting policy for the exact description of the voting scope https://www.amundi.com/institutional/
41. See Principle 3 to see our policy regarding potential conflict of interest

140 Stewardship Report 2022

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b. How we voted in 2022
Key outcomes of 2022 voting campaign
In the 2022 voting season, opposition votes
were made for five main reasons:– Unbalanced remuneration practices or lack of
ESG/ climate-related KPIs,– Lack of diversity and independence in thecomposition of boards of directors,– “Over-boarding” - when a board member
has, in our view, more executive and/or
non-executive positions that he or she canreasonably discharge to a high standard,– Failure to factor in climate issues orquestionable social practices, and– Unsustainable dividends and excessive capitalauthorisations.
Where possible, Amundi endeavours to alert
issuers if it intends to vote in opposition bysending an email prior to the meeting. This will
explain the rationale for the intended voting
stance.

21%

Opposition Rate Globally

In 2022, the opposition rate on compensation
was

38%

In 2022, the opposition rate on dividends was

7%

Executive compensation
Amundi considers that the alignment ofmanager and shareholder interest is a key
part of corporate governance and companies’
remuneration policy must reflect and maintainthis balance. In 2022, Amundi paid close
attention to whether executive remunerationplans and practice rewarded short-term targets
at the expense of long-term growth, as well asbalancing the different stakeholders’ efforts.
We also scrutinised the inclusion of ESG KPIs,

The 2022 voting campaign was also characterisedby the high number of proposals relating toEnvironmental and Social (E&S) issues, as thenumber of shareholder proposals on theseissues continued to rise globally. In the US,
companies from the S&P 500 received a record
642 proposals in the 2022 season, representing
a 5% increase versus 2021. E&S-related proposals
represented a large majority of all proposals
received by Russell 3000 companies: 58% of
proposals in 2022 compared to 51% in 2021,
based on data from The Conference Board.
Climate remained a focus of investors’ attention
during the 2022 proxy season, with more than
100 proposals. Requests for increased climaterelated disclosure have typically received higher
support from shareholders, with 11 proposals
securing majority support (for instance, at
Boeing, Chevron and Exxon Mobil). More broadly,
the increase in volume meant a decrease inaverage shareholder support, due in part to anumber of overly prescriptive proposals, butalso to the spread of “anti-ESG” proposals.

87%

In 2022, Amundi supportedof climate-related shareholder resolutions
presented at the General Meetings in which it
participated.
In 2022, Amundi supported

83%

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

and KPIs related to climate for issuers from highimpact sectors, at board, executive and ideallysenior management level.
Dividends
We strongly believe that dividend policies should
balance shareholders’ need for income, with theneed to preserve the financial strengths of thecompany, as well as the long-term interest of
employees to pave the way for future earnings
growth.

141 Stewardship Report 2022

Climate strategy
We supported a large majority of shareholder
resolutions calling for more transparency andinformation on ESG and climate strategy. Thiswas recognised by ShareAction’s “Voting
matters 2022” report, in which Amundi ranked
among the top performing asset managers interms of voting on climate change, climaterelated lobbying, and social issues.

October 2023

Social, healthresolutions

&

human

rightsrelatedSocial, health & human rights-related resolutions
have increased at General Meetings.

Board structure
Amundi expects to have a full understanding of
the functioning of the governance bodies of thecompanies in which it invests, including:– the level of independence,– existence and operation of specialisedcommittees,– skills and background balance,– adequate availability of directors (absence of“over-boarding”)

Illustration 21: Say on Climate
While Say on Climate as a topic emerged in 2021, 2022 was the year the new consultative
vote on companies’ climate strategy really expanded throughout Europe and Australia acrossa wide range of industries. Amundi voted on over 48 ‘Say on Climate’ resolutions proposedby the boards of companies. In the United States, no companies submitted a Say on Climate
this year, which could be explained by the opposition to this type of vote voiced by someinvestors in this market, however, the number of shareholder proposals on climate increased
yet again. Amundi continued engaging with companies in 2022 to recommend they include
Say on Climate on the agenda of their General Meetings.
Amundi adopted a demanding approach to the analysis of Say on Climate resolutions in the2022 season, a practice it encouraged in 2021 by voting mainly in favour of these resolutions.
In 2022, Amundi asked the companies that submitted a climate strategy at their General Meetings
to present comprehensive targets (in terms of figures, scope and baseline scenarios), a precise
agenda (short, medium and long-term objectives) as well as clear resources to achieve theirclimate goals (including a three- to five-year investment plan), before analysing each strategy inits entirety to assess its soundness and alignment with the Paris Agreement. This approach led
to a differentiated and case-by-case exercise of our votes on the climate strategies submitted
to shareholders. Of the 47 Say on Climate resolutions42 tabled by companies this year, Amundi
supported a total of 38%.
All companies concerned by a negative vote were informed of the reasons and we shared our
expectations as regards improvements to their strategy.

42. The companies with dual listing that submitted a Say on Climate at each of the entity’s AGM were counted as one.

142 Stewardship Report 2022

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Case study 30: Say on Climate
Outside of Europe, Australia recorded the highest number of Say on Climate proposals during
the 2022 proxy season, with eight companies in the Mining, Utilities and Energy sectors
proposing a vote on their climate transition plans. It was also the market with some of themost contested proposals, including the vote at Santos Limited, which saw 34% opposition, orthat of Woodside Energy Group, which registered dissent of 49%. This level of contestation isevidence that investors are looking closely at the Say on Climate votes and are not hesitating
to express their opposition to inadequate climate strategies, rather than an expression of voter
disagreement with the principles of Say on Climate.

Woodside Energy Group
Amundi was among those who voted against Woodside’s Say on Climate proposal. While
we praised recent positive developments in the company’s energy transition strategy,
we encouraged the company to bolster its Net-Zero ambition, suggesting they limit theirdependence on carbon offsets to achieve CO2 reduction goals in favour of operational
improvements, and to further consider profitable options to develop low-carbon solutions anddeep emission abatements aligned with 1.5°C scenarios.

c. 2022 Voting statistics
The Amundi Corporate Governance team conducted dialogue with 1,031 issuers in 2022.
Number of issuers
Voting Intentions’ alerts*

624

Dialogues triggered by voting alerts**

205

Pre-AGM and Off-Season Engagements

202

TOTAL

1,031

* With no further dialogue** With no off-season dialogue

Geographic breakdown of issuers dialogue

Number of engagements

700

622

600
500
400
272

300
200

183
150

100
0

Developed Asia

Source : Amundi Asset Management

Emerging Markets

EuropeNorth America

143 Stewardship Report 2022

October 2023

Overview of Amundi voting statistics over the last 4 years
Voting statistics

2019

2020

2021

2022

Number of companies voted

2,931

3,397

4,008

7,554

Number of meetings voted

3,474

4,241

7,309

10,208

Meetings voted with at least one vote “Against Management”

56%

71%

64%

69%

Number of items voted

41,34649,96077,631

107,297

Number of items voted “Against Management"*

13%

20%

20%

21%

Votes “Against Management”

2019

2020

2021

2022

Number of items voted “Against Management”

5,413

10,032

15,30322,550Board structure

11%

19%

20%

24%

Compensation

27%

31%

45%

38%

Financial Structures

21%

28%

21%

20%

Proportion of votes “Against/Category”

7%

Dividends (*)
Shareholder proposals (**)

43%

49%

32%

35%

Other

5%

11%

8%

8%

Vote in favour of Shareholders proposals

2019

2020

2021

2022

Number of Shareholder proposals

1,107

1,346

2,261

2,730

% of votes in favour of shareholder resolutions

65%

67%

77%

68%

Climate

81%

87%

86%

87%

Social/Health/Human Rights

70%

81%

83%

81%

ESG Items

2019

2020

2021

2022

Environment / Climate

133

148

196

277

Social

4,380

5,503

7,398

9,003

Governance

36,83344,30970,03798,017

Breakdown / theme(*) A new “Dividends” category was created in 2022. These proposals were previously recorded in the “Other” category.
(**) Does not include votes for which there was no management recommendation. Source: Amundi Asset Management

144 Stewardship Report 2022

October 2023

Geographic Breakdown of Meetings Voted by Region (2022)
4500

4231

4000
3500
3000

2554

2500
1949

2000

1474

1500
1000
500
0
Developed
Asia

Emerging
Markets

EuropeNorth
America

Source: Amundi Asset Management

4. Non-equity asset classes __________________We recognise that as fixed income investors we
do not often have the same voting opportunities
as other asset classes, but that our responsibilities
and the role we are able to play in influencing
issuers is by no means diminished for this reason.
Rather, as a significant debt investor with €605

bn assets under management at the end of2022, we have the influence and the leverage tomotivate significant change at the issuer level,
and the resource and expertise to contribute toprogressive and sustainable restructuring in thecase of default.

a. Fixed Income
In case of an event at the bond level triggering avote, the fund manager can express their view via
the ALTO front office tool by the same processused to manage the corporate action. The fundmanager will consider the value creation as wellas level of risk induced in their voting decision.

How we engage with fixed income issuers, forexample in case of default and/ or when Amundi
is a member of the restructuration steeringcommittee, can be found in Principles 9 – 10.

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b. Real Assets
Illustration 22: Private Equity
Amundi Private Equity Funds follow the Amundi Asset Management voting policy in theircompany interactions, with a focus on two societal issues:– The energy transition, in particular the decarbonisation of the economy– Social cohesion, particularly employee welfare and profit-sharing systems in privatecompanies.
Once we invest in a Private Company, we have a seat at the supervisory board and, as such,
have certain voting rights at this level. We are committed to accompanying the company on
its sustainability journey and to this end we define an ESG roadmap with each of our investee
companies.
For examples of how we engage with Private Equity holdings please see Principle 9.

5. Voting in practice _________________________
Chevron - Climate Strategy
At the 2022 AGM of the US oil company
Chevron Corporation, Amundi supported threeshareholder resolutions related to climate.
The first asked the firm to set targets in line withthe 2015 Paris Agreement, which aims to halve
emissions by 2030. It received support from
33% of shareholders.
The second resolution asked the company toreport on the potential financial impact of the
IEA Net-Zero scenario in 2050 for the company.
This resolution was supported by 39% of votes.
Lastly, the third proposal sought disclosure ofa report on the monitoring and managementof methane emissions from the company’s
operations. This resolution was overwhelmingly
adopted with 98% of votes in favour.
Amundi voted against the re-election of allboard members in light of concerns about thecompany’s climate strategy and its lobbying
practices. The lead director received the highest
level of dissent votes against his re-election with
12.8%. We wrote to the company to inform themof our votes.

Centrica - Climate performance
metrics
Centrica plc is a British multinational energy andservices company that predominantly operates
in the United Kingdom, North America and
Norway. It was identified as one of the world’s
largest corporate greenhouse gas emittersby the Climate Action 100+ investor coalition.
As the company sits in a climate-sensitive
sector, it is even more important that Centrica
recognises it has a role to play in addressingthese urgent challenges, and should therefore
be looking to manage these risks by integrating
related performance metrics into executive pay.
Amundi informed the company in June 2022
that we would support neither the remuneration
report nor the remuneration policy, as a directconsequence of the company’s poor disclosure
on climate targets and weights. Centrica did not
answer to our request.

146 Stewardship Report 2022

Thermador Groupe - Separation of
Chair and CEO roles
Amundi prefers the functions of chairman andchief executive officer to be separate. Where
the two roles are combined, the board should
provide detailed explanations with the reasonsjustifying this dual function. In such cases,
Amundi recommends the nomination of a leadindependent director, with specific and distinct
functions.
At the 2022 AGM of Thermador Groupe, themandate of the chairman/CEO was submitted
for renewal. Amundi voted against the resolution
due to the absence of a lead independent
director, and undertook active engagement withthe company. Twelve percent of shareholders
voted against the re-election of the chairman/
CEO, which reflects the alignment of shareholder
expectations on this issue.
A few days after our engagement, the company
informed Amundi that the nomination of a leadindependent director had been added to theagenda of the next board meeting. Amundi will
monitor changes to the board composition andwill continue to engage with the company toreinforce our preference for a clear distributionof powers that limits conflicts of interest.

October 2023

Amazon.com - Health & Human rights
related resolutions
The 2022 AGM of Amazon.com, the US online
retailer, illustrates clearly the differing ways
Amundi takes voting decisions based on acomprehensive analysis of companies, including
environmental and social aspects.
Amundi voted against the retailer’s Say on
Pay, on the grounds that the chief executive’s
remuneration is excessive compared to peers,
and also due to the absence of relevant ESG
metrics associated with variable pay. The
proposal received 44% of votes against.
Regarding board appointments, we opposed
the renewal of the Audit Committee Chair in lightof the recurring controversies over workplace
conditions. There have been numerous reports
and allegations concerning the company’s
lagging employment practices, in particularregarding health and safety, but also on the
topic of collective bargaining.
Amundisupported
multipleshareholder
proposals, including a proposal requesting that
non-management employees be considered on
the list of prospective Board candidates. Amundi
is in favour of employee representation and webelieve it would be particularly beneficial forcompanies with large workforce like Amazon.
com. This proposal recorded 22% support fromshareholders. Amundi also voted in favour ofseveral proposals requesting that Amazon.com
improve its disclosure on working conditions(44% support), the protection of worker rights(39% support) as well as a report on plastic
reduction (48% support). We explained ourvoting decisions to the company. Amundi isconsidering potential next steps to escalate thematter, including filing shareholder proposals.

147 Stewardship Report 2022

Apple - Social, Health & Human rights
related resolutions
Apple, through some of its suppliers, is one of
the many companies named in the controversy
over treatment of Uyghur people in recent
years, including in the 2020 “Uyghurs for Sale”
report published by the Australian Strategic
Policy Institute. As such, a shareholder
submitted a proposal at the 2022 AGM of the
US-multinational asking the board of directors
to oversee the preparation of a report on theextent to which Apple’s policies and procedures
effectively protect workers in its supply chain
from forced labour.
On the grounds that such additional disclosure
could enable better assessment of the company's
related policies, the requested report could
contribute to the company's long-term value
creation as well as reducing reputational andlegal risks. Amundi therefore voted in favour ofthe shareholder proposal which received 34%
support.

October 2023

McDonald’s Corporation – Social,
Health & Human rights related
resolutions
At the 2022 AGM of the worldwide fast-foodchain, Amundi supported a shareholder proposal
requesting a public report on the public healthcosts of antibiotic use in agriculture. Excessive
reliance on antibiotics in raising animals forfood –including McDonald's meat supply chains– contributes to antimicrobial resistance (AMR),
which threatens global health by reducing theeffectiveness of antibiotic drugs. Adequatetransparency on the matter is in shareholders’interest to ensure the company take into accountall costs and risks its market or business model
may face.
Shareholders representing 13.19% of the votes
supported the proposal. A similar proposalthat was co-filed by Amundi the previous year
had received the support of 11.27% of shares
voted. This increase in support may evidence
that more investors are becoming aware of the
public health risks associated to AMR.

148 Stewardship Report 2022

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Appendix
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.

42Signatories’ governance,
resources and incentives support
stewardship.

13

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.

54

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.

77

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.

113

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.

136

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.

47

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CanadaOctober 2023

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.

4

2

Monitor companies

7

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

54

3

Monitor companies

6

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

47

12

Signatories actively exercise theirrights and responsibilities.

136

4

Engage with companies

9

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

77

5

Collaborate with other institutional
investors

10

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

113

6Work with policy makers

4

Signatories identify and respondto market-wide and systemic risks
to promote a well-functioning
financial system.

30

7Focus on long-term sustainable value

2

Signatories’ governance,
resources and incentives support
stewardship.

13

7

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

54

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Italy

October 2023

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

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.

42Signatories’ governance,
resources and incentives support
stewardship.

13

2

IMCs should monitor their investee
companies.

7

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

54

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.

77

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.

113

5

IMCs should exercise their voting
rights in a considered way.

12

Signatories actively exercise theirrights and responsibilities.

136

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.

47

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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.

42

Institutional 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 first.

25

3

Institutional 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.

54

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.

77

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.

136

6

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

6

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

47

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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.

13

8Service providers for institutional
investors should endeavor 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.

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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 2023.

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