Exclusion Policy on

Cluster Munitions and Anti-personnel Mines
July 2024
This policy applies to the group of legal entities whose parent company is Columbia Threadneedle
Investments UK International Limited and which formerly traded as BMO Global Asset Management
EMEA. These entities are now part of Columbia Threadneedle Investments which is the asset
management business of Ameriprise Financial, Inc.

Background
At Columbia Threadneedle Investments we recognise thevalue in effectively integrating environmental, social andgovernance factors into our investment processes. Ourconviction in this approach was evidenced in Europe bysigning up to the Principles for Responsible Investment
in 2006. In applying these Principles, we identified theneed to enhance our ownership policies to improvestakeholder protections. This controversial weapons
policy was created in response to the UN Convention on
Cluster Munitions and the UN Anti-Personnel Landmines
Convention, and governs all active strategies managed
by subsidiaries of Columbia Threadneedle Investments
UK International Limited, part of Columbia Threadneedle
Investments, EMEA.

PolicyIssuers that develop, manufacture, provide maintenanceor sell cluster munitions or anti-personnel mines areexcluded.

The policy does not apply to:n Mandates designed to track indices, including index
ETFs1
n Segregated client mandates whose investment
guidelines prevent the application of the exclusions
without further revision or whose portfolios would
otherwise be materially affected by the exclusions.
In such circumstances we will consult with clients
about making amendments to accommodate theseexclusionsn Investment funds (public or private) whose offering
documents would currently not allow the applicationof the exclusions without further revision or whose
portfolios would otherwise be materially affected bythe exclusions. In such circumstances we will seek,
where possible, to make the necessary amendments
to the investment guidelinesn Any mandates managed by Pyrford International
LimitedIf an investment becomes exposed to excluded activities,
it should be divested as soon as possible, and no later
than 30 calendar days.*n Any mandates that are prohibited from applying theexclusions because of the requirements of applicablelaw and/or regulation, including ERISA mandates in theUnited States.

ScopeIn addition, the following investments are considered outof scope of this policy:

The exclusions cover investments in publicly-listed andprivate equity, and interest-bearing securities/commercial
paper (including those issued by directly affiliated financial
vehicles).

*1n Investments in index tracking products or derivativesn Investments in third-party managed investment funds(whether public or private). However, we will engage withthose third-party managers to encourage them to adopt
equivalent exclusions.

In exceptional circumstances, the Head of Asset Class may approve an extension to divest in accordance with the applicable regulatory requirements.
“ Passive” investment vehicles are considered to be any fund or ETF with an investment objective that tracks a specific index or utilizes a portfolio construction
methodology based on a defined set of rules which must be followed to achieve a targeted exposure or outcome.

Exclusion Policy on Cluster Munitions and Anti-personnel Mines

Implementation
In implementing this policy, we engage a third-party research provider to help identify issuers involved in thedevelopment, manufacture or sale of cluster munitions or anti-personnel mines. The exclusion of in-scope issuers
follows a defined process involving Compliance and Responsible Investment. Our procedures and exclusion list are
reviewed and updated on an annual basis.

To find out more, visit columbiathreadneedle.com
Important information: This document is intended for informational purposes only and should not be considered representative of any particular investment. This should not be considered an offer
or solicitation to buy or sell any securities or other financial instruments, or to provide investment advice or services.
Investing involves risk including the risk of loss of principal. Your capital is at risk. Market risk may affect a single issuer, sector of the economy, industry or the market as a whole. The value ofinvestments is not guaranteed, and therefore an investor may not get back the amount invested. International investing involves certain risks and volatility due to potential political, economic orcurrency fluctuations and different financial and accounting standards.
The views expressed are as of the date given, may change as market or other conditions change and may differ from views expressed by other Columbia Threadneedle Investments (ColumbiaThreadneedle) associates or affiliates. Actual investments or investment decisions made by Columbia Threadneedle and its affiliates, whether for its own account or on behalf of clients, may notnecessarily reflect the views expressed. Investment decisions should always be made based on an investor’s specific financial needs, objectives, goals, time horizon and risk tolerance. Asset classes
described may not be suitable for all investors.
Information and opinions provided by third parties have been obtained from sources believed to be reliable, but accuracy and completeness cannot be guaranteed.
In Australia: Issued by Threadneedle Investments Singapore (Pte.) Limited [“TIS”], ARBN 600 027 414. TIS is exempt from the requirement to hold an Australian financial services licence under theCorporations Act and relies on Class Order 03/1102 in marketing and providing financial services to Australian wholesale clients as defined in Section 761G of the Corporations Act 2001. TIS isregulated in Singapore (Registration number: 201101559W) by the Monetary Authority of Singapore under the Securities and Futures Act (Chapter 289), which differ from Australian laws.
In Singapore: Issued by Threadneedle Investments Singapore (Pte.) Limited, 3 Killiney Road, #07-07, Winsland House 1, Singapore 239519, which is regulated in Singapore by the Monetary Authorityof Singapore under the Securities and Futures Act (Chapter 289). Registration number: 201101559W. This advertisement has not been reviewed by the Monetary Authority of Singapore.
In Hong Kong: Issued by Threadneedle Portfolio Services Hong Kong Limited 天利投資管理香港有限公司. Unit 3004, Two Exchange Square, 8 Connaught Place, Hong Kong, which is licensed bythe Securities and Futures Commission (“SFC”) to conduct Type 1 regulated activities (CE:AQA779). Registered in Hong Kong under the Companies Ordinance (Chapter 622), No. 1173058.
In UK: Issued by Threadneedle Asset Management Limited. Registered in England and Wales, Registered No. 573204, Cannon Place, 78 Cannon Street, London EC4N 6AG, United Kingdom. Authorizedand regulated in the UK by the Financial Conduct Authority.
In the EEA: Issued by Threadneedle Management Luxembourg S.A. Registered with the Registre de Commerce et des Societes (Luxembourg), Registered No. B 110242, 44, rue de la Vallée, L-2661
Luxembourg, Grand Duchy of Luxembourg.
In Switzerland: issued by Threadneedle Portfolio Services AG, Registered address: Claridenstrasse 41, 8002 Zurich, Switzerland. This document is distributed by Columbia Threadneedle Investments(ME) Limited, which is regulated by the Dubai Financial Services Authority (DFSA). For Distributors: This document is intended to provide distributors’ with information aboutGroup products andservices and is not for further distribution. For Institutional Clients: The information in this document is not intended as financial advice and is only intended for persons with appropriate investment
knowledge and who meet the regulatory criteria to be classified as a Professional Client or Market Counterparties and no other Person should act upon it.
Columbia Threadneedle Investments (Columbia Threadneedle) is the global brand name of the Columbia and Threadneedle group of companies. columbiathreadneedle.com
Issued 07.24 | Valid to 07.25 | WF2380367