T. ROWE PRICE GLOBAL IMPACT CREDIT STRATEGYIMPACT STATEMENT

January 2023

As our world evolves, societal, governmental, regulatory,
and fiduciary pressures are driving change on a range ofenvironmental and social fronts. As companies respondand increasingly shift investment to address globalpressure points, the opportunity to invest in a businessthat creates a positive impact on society and the planet isbroader than it has ever been in public debt markets. We
believe impact investing is vital in positioning investors
to invest on the right side of societal and environmental
change. It creates a real opportunity to select investmentsthat we believe will deliver a favourable impact profile andcapture the added return potential that this can bring.
We strongly believe that impact is achieved within an
investment portfolio in more ways than simply investing

and capturing the economics and activities of certain typesof companies. It involves directing fresh capital toward
desired impact outcomes, impact-oriented company
engagement, and the associated influence feedback loop.
Our investment process embeds clear principles ofmateriality and measurability to form the basis for
identifying positive impact for clients. We aim to make adifference with our capital as a fixed income manager,
and hope to accelerate this change through engagement.
Due to the very complex friction points that exist for ourplanet and global communities, delivering impact requires
patience and an understanding of change. This is why
being resilient in applying an impact-oriented investment
approach is imperative.

Our Impact Charter

Material

Measurable

We base our security
stock inclusion
criteria oncriteria
inclusiona corporation’s
on anactivitiesactivities
issuer’s
and theirandalignmentitswith clearlywithalignmentdeﬁnedclearly
impactpillars, always
deﬁnedimpactaccounting
pillars, always
for dimensionsof positive
accounting
for dimensions
futurechange.
ofpositive
future change.

We quantify outcomes bothindividually and collectively
as we translate impact
intentionality into ameasurement framework.

Additional

Resilient

We aim to capture positiveenvironmental and social
outcomes on a global basis,
but we also commit to using
our scale and resources topromote and progress theimpact agenda.

In an era of disruption andextreme outcomes, positivechange has to be durable.
Patience and collaboration
will be key in pursuing goodclient outcomes.

FOR INVESTMENT PROFESSIONALS ONLY. NOT FOR FURTHER DISTRIBUTION.

Impact is about
the present, but
includesdimensions ofchange andpersistence
persistence.
Impact requires
conscious
action, skilled
execution andthe commitmentof additionality.

MATERIAL POSITIVE IMPACT

Systematic and proactive integration of ESG considerations

All our investments start with a security-by-security
assessment of impact materiality. Our responsible
investing team defines our impact universe throughcareful screening, a deep understanding of environmental,social and governance (ESG) factors, industry-specific,
forward-looking impact inclusion criteria and an evaluationof the credibility of the ESG-labelled bonds through ourproprietary framework.

The Global Impact Credit strategy leverages our ESG
integration process to understand environmental andsocial dynamics related to a company’s conduct. All of our
securities selection decisions begin with a clearly defined
positive impact thesis, which proactively and systematicallyintegrates ESG considerations. Our philosophy is that ESG
factors cannot be separate or tangential parts of a traditional
investment thesis. Company fundamentals, including its
consideration of environmental, social and governancefactors, play a critical role in the security selection process.

Avoiding significant harm: T. Rowe Price Impact
Exclusion List
The initial global aggregate credit opportunity set ofaround 3,500 issuers (the Bloomberg Global-Aggregate
Credit Index) is screened* to exclude areas of the global
economy that, in our view, generate significant harm.
We also exclude securities that screen out individuallyon conduct-based metrics, integrating our proprietary
Responsible Investing Indicator Model (RIIM) analysis to
identify specific controversies or areas of ESG risk thatmerit individual consideration.

The process of ESG integration takes place on three levels:
1. First, as our fundamental and responsible investing
research analysts incorporate environmental, social,and governance factors into their analysis;
2. Second, as we use T. Rowe Price’s proprietary RIIM
analysis at regular intervals to help us understand the
ESG characteristics of securities and the aggregate
portfolio; and3. Third, as the portfolio manager integrates ESG
considerations within the investment thesis andportfolio construction process itself.

The T. Rowe Price Impact Exclusion List currently consists of the following categories:
Adult Entertainment
companies that generate >5% of revenues
from adult entertainment.

For-Profit Prisonscompanies that generate >5% of revenues
from for-profit prisons.

Alcohol
companies that generate >5% of revenues
from alcohol.

Fossil Fuels
companies that generate >5% of revenues
from the production of thermal coal, andcompanies that are identified within the Oilor Gas industry through the Global Industry
Classification Standard (GICS) and/or
Bloomberg Industry Classification Systems(BICS) classification.

Assault-style Weapons
companies that manufacture or retail semiautomatic weapons for civilian use.

Gambling
companies that generate >5% of revenues
from direct gambling operations.

Controversial Weapons
companies with direct exposure to antipersonnel land mines, cluster munitions,
incendiary weapons, biological weapons,chemical weapons and/or nuclear weapons.

Tobaccocompanies that produce tobacco or key
components of tobacco products.

Conventional Weapons
companies that generate >5% of revenues
from the production of conventional weapons.

Conduct-based
corporate or sovereign issuers that, in theopinion of the investment manager, have been
involved in an extreme environmental, social,
ethical or governance breach as determinedin reference to the UN Global Compact
principles and are not taking adequate steps
to remediate the issue.

* Screening is generally applied only to the relevant company itself and to its subsidiaries. Minority holdings (less than 50% ownership) are generally not considered forscreening purposes.

2

Aligning our investments to the United Nations
Sustainable Development Goals (UN SDGs)

Companies must meet at least one of the following four
impact inclusion criteria to be eligible for consideration:

Our strategy philosophy aligns with the UN SDGs, aglobally recognised framework designed to end poverty,
protect the planet, and ensure prosperity. We believe this isthe best way to align all stakeholders in the impact journey,encompassing our clients, investment team, and thebusinesses our strategy owns.

1. Majority of current revenues or profits is tied to at least
one impact sub-pillar

3. Use of proceeds are allocated to projects tied to at least
one impact sub-pillar
4. Best-in-class response to impact situations
Pursuing positive impact from our investments against
these pillars is the start point for every investment decision
we make.

1 2 3Social equity and qualityof lifeClimate and resource
ImpactSustainable innovation andproductivity

1.

Reducing greenhousegases (GHGs)

4.

Enabling social equity

7.

Sustainable technology

2.

Promoting healthy
ecosystems

5.

Improving health8.

Building sustainableindustry & infrastructure3.

Nurturing circular
economies

6.

Enhancing quality of life

UN SDG
Alignment

T. Rowe Price Pillars & Sub-pillars

To ensure our approach has substance and materiality,
we adopt a forward-looking perspective on change while
ensuring all investment decisions are based on a clearly
defined, positive impact thesis that is both material andmeasurable. We assess business activities and how theyalign to the following three impact pillars and eight subpillars, guided by the UN SDGs:

2. Majority of projected revenues or profits in 10 years is
tied to at least one impact sub-pillar

T. Rowe Price uses a proprietary custom structure for impact pillar and sub-pillar classification.
The UN SDGs encompass 17 goals. For further information, please visit http://www.un.org/sustainabledevelopment/sustainable-development-goals/
The trademarks shown are the property of their respective owners. Use does not imply endorsement, sponsorship, or affiliation of T. Rowe Price with any of the
trademark owners.

Evaluating the credibility of ESG-labelled Bonds
Our Global Impact Credit strategy leverages our proprietary
ESG bond framework to assess the credibility of ESGlabelled bonds to enhance our research and promote better
decision making. By evaluating the ESG-labelled bonds indepth, we aim to safeguard ourselves against greenwashedbonds and ultimately identify high impact projects.
The process of evaluating ESG-labelled Bonds:
Our fundamental and responsible investment analysts assesseach ESG-labelled bond using our proprietary framework.
First, our fundamental and responsible investment analysts
evaluate the issuer’s ESG profile based on our proprietary
Responsible Investing Indicator Model (RIIM) score,
together with an assessment of the issuer’s environmental
and/or social targets and commitments.

We then verify alignment with standards put forth by theInternational Capital Markets Association (ICMA), second party
opinion solicitation, and an assessment of the governancestructure supporting the sustainable finance framework.
We further evaluate the use of proceeds and credibilityof the financed projects. Performing such analysis helps
filter out greenwashed bonds and ultimately identify highimpact projects.
The final step of our evaluation involves post-issuancereporting to ensure the targeted ESG bond stays true to
its label.
Each bond is rated green, orange, or red based on its
weighted average overall score.

3

Evaluating ESG-labelled Bonds
We utilize a proprietary framework for assessing the credibility of ESG-labelled bonds

How it works
 Analysts assess ESG

Issuer’s ESG
Profile Proprietary

T. Rowe Price
RIIM score

 Issuer’s

environmental
and/or social
targets/
commitments

Framework,
Standards,
Verification
 ICMA alignment
 Second party

opinionUse ofProceeds
 Credibility ofallocation ofproceeds

management
and allocation

 Governancestructure Reported

proceeds

 Proceeds

Post-Issuance
Reportingbond frameworks
across 4 pillars and
12 sub-pillars, each
rated Green, Orange
or Red A weighted average Audit reporting Refinancing
 Addressing

ineligibility

overall score is
assigned to theframework andintegrated into theinvestment decision
process

Our ESG bond model aims to guard against greenwashing and identify high impact projects
Responsible Investing Indicator Model (RIIM) is a proprietary tool developed to enhance research and aid better decision making. RIIM rates companies in a traffic lightsystem measuring their environmental, social and ethical profile and flagging companies with elevated risks (Green=No/Few Flags, Orange=Medium Flags, Red=High Flags).

MEASURABILITY
Quantifying and measuring outcomes is one of the mostsignificant challenges impact investors face. This is dueto the lack of generally accepted measurement standards
and the need to capture the evolving dimension of change,
not just a backwards-looking data set of historical impacts.
Networks of impact investing professionals, including asset
managers, continue to evolve and establish harmonised
terminology, frameworks, and principles, to increase
reporting clarity to clients. Due to the rapid development in
impact management and measurement best practices, we
keep our approach under constant review.
Impact due diligence: assessing fundamentals and risk
We use the five dimensions of impact framework* to carry out
the impact due diligence of a given security. This framework

was developed by the Impact Management Project, an
impact practitioner community of over 2,000 organisations.
This framework leads to assessing a company’s ability todeliver impact on a holistic basis, including the risks that
may affect its ability to deliver the targeted impact.
The five dimensions are:
1. What outcome is occurring in the period?
2. Who experiences the outcome?
3. How much of the outcome is occurring (scale, depth,and duration)?
4. Contribution—Would this change likely have happened
anyway? and5. Risk—What is the risk to people and the planet if the
impact does not occur as expected?

Our approach to impact measurement
Quantify alignment with ourthree impact pillars and eight
sub-pillars
To create a robust andmeasurable impact universe

Alignment

Fundamentals

Measure outcomes
and impact
Using the theory of change,quantifying wherever possible,
using external data

Outcomes
Assess fundamentals throughan impact lensUsing the Impact Management
Project’s five dimensions of impact
to gain a deeper understanding ofa business’ impact footprint

Understand impact risk
Qualify risks and track evolution
and impairment of the impact
thesisRisk

The Impact Management Project, a project by Bridges Fund Management Ltd (company number 10401079) (“Bridges”).
* The Five Dimensions of Impact is a measurement framework developed by the Impact Management Project, an impact practitioner community of over 2,000 organizations.

4Within this process and depending on data availability, we
also use guidance and metrics from the IRIS+ catalogueof metrics, developed by the Global Impact Investing
Network (GIIN).
This analysis leads us to formalise an impact thesis,
highlight negative externalities and risks and define key
performance indicators (KPIs) for each security.
This impact-oriented due diligence can also be a starting
point for engaging with a company. During this stage, theinvestment and responsible investing teams may identify
gaps in the disclosures, which are necessary to the impact
measurement process.
Outcome and impact measurement
In our end of year annual impact report, we provide a
portfolio review to give clarity to clients on our ownershipand impact successes, engagements, and sell-driven
events where necessary. We measure individual andaggregate impact where we can and aim for clarity without
over-simplifying a complex equation.
We plan to release our next annual impact report in
the second half of 2023 and believe that the ‘Theory of
Change’ model provides a clear and comprehensive
framework for evaluating how the efforts of each holding isdelivering impact, through the measurement of achieved
outcomes. This framework explains the steps taken by acompany to produce specific societal and environmental
outcomes on a chronological basis.
One benefit of this approach is it provides a robust
benchmark against which we can measure theeffectiveness and progress of a company toward its impact
goals over time.
For investment in companies that undertake multiple
activities leading to complementary or conflicting
outcomes, we will endeavour to reflect this complexity in
our methodology and our annual report using case studies.
ADDITIONAL: ACCELERATING IMPACT THROUGHENGAGEMENT
We truly believe impact is achieved within an investment
portfolio in more ways than simply investing in acompany and capturing the economics and activities. Our
approach involves directing fresh capital towards desired
impact outcomes alongside impact‑oriented company
engagements, and the associated influence feedback loop.
Done well and in partnership with our fundamental andresponsible research analysts and governance team, we
believe this will potentially create benefits not only for our
Global Impact Credit clients, but other investors.
Engagement ProgrammeEngagement is a crucial tool for impact managers to track
a company’s progress towards its impact goals and toprovide guidance on sustainability best practices whenneeded.

The central focus of our engagement program is at thecompany level. Generally, we do not identify broad themes
and then engage with multiple companies on the same
issue. We identify specific factors through our researchthat could be potential impediments to a security’s
performance. We may at times suggest to a company thatthey make a specific change, or we may seek to gain more
information on an ESG issue to ensure our investment
decisions are well-informed. We believe this companyspecific approach results in the highest impact because it
is aligned with our firm’s core investment approach: active
management rooted in fundamental investment analysis.
Thanks to the trust our clients have placed in us,
T. Rowe Price is a significant investor in many of the world’s
leading companies. This affords us, in most cases, accessto company management that we find highly valuable inboth engagement and insight terms. This allows us to:a. see the potential to accelerate the good aspects of theiroperations whileb. helping to mitigate the negative externalities which
naturally exist, even in the purest of business operations.
Part of our additional role will be pursuing an agenda ofgreater disclosure by businesses to assist in assessing andmeasuring impact for our client base.
We measure the success of our engagement throughmaintaining a regular dialogue with the management
teams of companies represented across our portfolios.
Our investment-driven engagement program frequently
identifies targets through our proprietary RIIM analysis,
governance screening, and analysts’ fundamental
research. As an active manager, company management
teams are aware that we have the option of selling ourinvestment. That means our investment-driven engagement
approach can yield meaningful outcomes.
Our objective is to use our influence to increase the probability
that the company will potentially outperform its peers,
enabling our clients to achieve their investment goals. We aim
to do this using various stewardship activities listed below:§ Regular, ongoing investment diligence§ Engagement with management on ESG issues§ Meetings with senior management, including offering
our candid feedback§ Meetings with members of the Board of Directors§ Decisions to increase or decrease the weight of aninvestment in a portfolio§ Decisions to initiate or eliminate an investment§ On rare occasions, public statements about acompany, either to support the management team or toencourage it to change course in what we view to be thelong-term best interests of the company.
We currently publish a quarterly engagement report ona selection of engagements and aim to summarise all
engagement activities relating to our Global Impact Credit
strategy in our annual impact report.

5Knowledge sharing
As an impact investor, we understand it is our responsibility
to promote and deepen impact investing practice. In thiscontext, we aim to be additional within our firm by using ourscale and resources to promote and progress the impact
agenda.
We expect to be able to share knowledge with our clients as
we bring our collective resources and insights together on aparticular subject. While we are at the beginning of our own
impact journey, we are commited to advancing the agenda of
impact investing with our global client base through thoughtpieces and openness of communication. We will continue todevelop in this area, in the spirit and practice of additionality.
RESILIENCE
In the same way that our environmental sustainability
journey requires resilience, commitment, iteration, andimagination, so too will the journey of investing for impact.
We aspire to be a partner to our clients, using our fullbreadth of ideas to harvest both impact and alpha over the
long-term with a deep analysis and a long‑term view acting
as a core driver of decision making.
A forward-looking approach enabled by deep researchcapabilities
Given the complexity and non-linear nature of delivering impact
and the patience it necessitates, adopting a long-term andholistic view when investing to solve sustainability challenges isnecessary. Looking forward is also one of the key componentsthat differentiate a backward looking index with a future
outcome in a world defined by change, a crucial aspect of
successful impact investing and adding value in the long term.
We integrate our security perspectives to identify, in ourview, underappreciated impact and mispriced economic
return improvement on a truly global, security-by-security
basis. We apply a forward-looking, research-driven, andhigh conviction approach to our investment decisions.
This is important with respect to prudent risk management
when it matters and aligning with the UN SDGs as we seek
to engage with the full breadth of impact opportunities thatexist in an evolving world.
GOING BEYOND GREEN BONDS
Impact investing in fixed income is not confined to the ESG
labelled bond market. Impact can be captured throughdirecting capital to issuers providing positive environmental
or social impact through their everyday activities.
Our investment process is thus not limited to green bonds
as we look to a broad opportunity set spanning acrossthe corporate and credit universe to identify the highest
impact-aligned issuers. By engaging and investing incompanies outside of the ESG-labelled debt market, we
can deploy our scale and resources to help progress anissuer’s impact agenda.
Examples include a not-for-profit children’s hospital, ora development bank which inherently carries a social
mission through its investment and lending activities.
Research, measurement, reporting, iteration
The challenge for the industry is that impact investing
lives in a complex world of risk and opportunity. We
formalise these considerations during the company’s
impact due diligence, derive an impact thesis, highlightnegative externalities and risks, and define key
performance indicators (KPIs). We aim to report thecompany’s progress towards its impact goals to ourinvestors annually in our annual impact report by tracking
the evolution of these KPIs.
We aim to be a good partner and contribute to innovationin the field of impact measurement and reporting, helping
clients navigate this journey with the data and trust theyneed. Leveraging multiple dimensions of our researchexpertise (both responsible and fundamental) while investingin the field of responsible investing and impact reporting will,
we believe, be a real advantage over the long term.
As an impact manager, we must be additional and commit
to engaging openly with businesses in the sustainability
journey. We will use our investment in the company asleverage to enter into dialogues with companies where
we can see the potential to accelerate the good aspectsof their operations, while helping to mitigate the negative
externalities which may exist in a business operations.
In this venture, we are committed to making our own
contribution by using our global research presence andcorporate scale to pursue outcomes that integrate financial
returns and align impact for future generations. Change willtake time and require resilience, but this is consistent withmany aspects of successful long-term investing.

6

Risks – the following risks are materially relevant to the portfolio:
ABS and MBS risk—Asset-Backed Securities (ABS) and Mortgage-Backed Securities (MBS) may be subject to greater liquidity, credit, default and interest rate risk
compared to other bonds. They are often exposed to extension and prepayment risk.
Contingent Convertible Bonds risk—Contingent Convertible Bonds may be subject to additional risks linked to: capital structure inversion, trigger levels, coupon
cancellations, call extensions, yield/valuation, conversions, write downs, industry concentration and liquidity, among others.
Credit risk—Credit risk arises when an issuer’s financial health deteriorates and/or it fails to fulfill its financial obligations to the portfolio.
Distressed or defaulted debt risk—Distressed or defaulted debt securities may bear substantially higher degree of risks linked to recovery, liquidity and valuation.
Default risk—Default risk may occur if the issuers of certain bonds become unable or unwilling to make payments on their bonds.
Derivatives risk – Derivatives may be used to create leverage which could expose the portfolio to higher volatility and/or losses that are significantly greater than thecost of the derivative.
Emerging markets risk—Emerging markets are less established than developed markets and therefore involve higher risks.
High yield debt risk—High yield debt securities are generally subject to greater risk of issuer debt restructuring or default, higher liquidity risk and greater sensitivity tomarket conditions.
Interest rate risk—Interest rate risk is the potential for losses in fixed-income investments as a result of unexpected changes in interest rates.
Liquidity risk—Liquidity risk may result in securities becoming hard to value or trade within a desired timeframe at a fair price.
General Portfolio Risks
Capital risk—the value of your investment will vary and is not guaranteed. It will be affected by changes in the exchange rate between the base currency of the portfolio
and the currency in which you subscribed, if different.
Counterparty risk—an entity with which the portfolio transacts may not meet its obligations to the portfolio.
ESG and Sustainability risk—May result in a material negative impact on the value of an investment and performance of the portfolio.
Geographic concentration risk—to the extent that a portfolio invests a large portion of its assets in a particular geographic area, its performance will be more strongly
affected by events within that area.
Hedging risk—a portfolio’s attempts to reduce or eliminate certain risks through hedging may not work as intended.
Investment portfolio risk—investing in portfolios involves certain risks an investor would not face if investing in markets directly.
Management risk—the investment manager or its designees may at times find their obligations to a portfolio to be in conflict with their obligations to other investment
portfolios they manage (although in such cases, all portfolios will be dealt with equitably).
Market risk—may subject the portfolio to experience losses caused by unexpected changes in a wide variety of factors.
Operational risk—operational failures could lead to disruptions of portfolio operations or financial losses.

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All investments are subject to risk, including the possible loss of principal. Impact investing may not succeed in generating a positive environmental or social impact.
A company’s ability to affect positive impact or T. Rowe Price’s assessment of a company’s positive social and environmental impact may change over time, which
could cause the portfolio to temporarily hold securities that are not consistent with the portfolio’s responsible investment principles.
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