Principles of Internal
Governance and Asset
Stewardship 2024

This disclosure is in accordancewith FSC Standard 23 andapplicable for Australia only.
As at June 2024

First Sentier Investors (FSI)
disclosure under FSC standard 23:
Principles of Internal Governanceand Asset Stewardship
The Financial Services Council (FSC) promotes bestpractice in the Australian financial services industry by
setting mandatory standards for its members and providing
guidance notes to assist in the operational efficiency ofindustry participants.

We provide additional information in our annual Responsible
Investment and Stewardship Reports and on our website.
As a global asset manager, we benchmark ourselves
against a number of global standards as they relate toasset stewardship.

In July 2017, the FSC issued Standard 23: Principles ofInternal Governance and Asset Stewardship. The Standard
is designed to guide and encourage Australian investment
managers to disclose how they apply internal governance toasset stewardship.

These include:

As stewards of client assets, asset managers have a fiduciary
responsibility to ensure they act in clients’ interests and treat
client assets with due care and diligence.
FSI has a long-held commitment to this stewardship principle,
and we are pleased to provide the following disclosure inaccordance with FSC Standard 23.

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Principles of Internal Governance and Asset Stewardship 2024

– CFA Institute’s Code of Ethics and Standards ofProfessional Conduct– Principles for Responsible Investment– Pensions and Lifetime Savings Association (PLSA)
Stewardship Disclosure Framework– UK Stewardship CodeThis disclosure is an update to our disclosure for the period
1 July 2023 to 30 June 2024.

Our disclosure
Organisational and investment approach
1. 	A description of the distinguishing features of the asset
manager, and how these features are directed towards
achieving client objectives
First Sentier Investors (FSI) is a global asset management
group and the home of investment teams FSSA Investment
Managers, lgneo Infrastructure Partners, RQI Investors (formallyknown as Realindex Investments) and Stewart Investors. In
November 2023, we added an investment team by forming astrategic partnership with AlbaCore Capital Group, a European
alternative credit specialist.
We are stewards of assets under management (AUM) of
A$226.8 billion (as at June 2024) across global and regional
equities, cash and fixed income, infrastructure, property andalternative credit on behalf of institutional investors, pension
funds, wholesale distributors and platforms, financial advisers
and their clients.
All of our investment teams operate with discrete investment
autonomy and investment processes, in line with theirinvestment objectives. Each team integrates environmental,social and governance (ESG) considerations in a way thatis suited to their investment philosophy and style, meaningthat teams may approach the same issues in different ways.
This tailored approach allows the teams to make decisions
in line with their fund objectives, while still benefiting fromthe resources and governance structures provided by thewider business.
While each investment team has a different investment
approach, all teams believe that markets are not completely
efficient and that value can be added for our clients throughcareful investment analysis and prudent decision-making.

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Principles of Internal Governance and Asset Stewardship 2024

2.

An explanation of how the asset manager aligns its
purpose and values with its duty to clients

At First Sentier Investors, our vision is to provide high quality,
differentiated and relevant investment capabilities to deliver
exceptional investment performance to our clients and ourshareholder. We do this through our independent teams ofactive, specialist investors who share a common commitment
to responsible investment principles.
We work together across multiple global markets, with over
1,000 employees collaborating to achieve our vision. Our
philosophy and culture are based on a set of shared values:• Care - We care about our clients, society and each other• Openness - We are open with each other and to different waysof thinking• Collaboration - We collaborate to deliver the best solutions• Dedication - We are dedicated to being experts in our
respective fields
Our Global Responsible Investment and Stewardship Principles
and Policy, which outline our approach to ownership on ourclients' behalf, are supported by policies and processes
overseen by the Global Responsible Investment Executive
Committee. The committee is chaired by First Sentier Investors'
Chief Executive Officer.
Our operating model has been designed to enable theinvestment teams to remain focused on their role as stewardsof client assets and on their core task of delivering long-term
investment outperformance for our clients. This operating
model is supported by a scalable operating platform thatprovides shared services and resources.

3.

An overview of the ownership, management and governance structures of the organisation

Ownership structureFirst Sentier investors is the standalone investment management business of Mitsubishi UFJ Trust and Banking Corporation, a wholly
owned subsidiary of Mitsubishi UFJ Financial Group, Inc. (MUFG), which is a publicly owned company listed on the Tokyo, Nagoya and
New York Stock Exchange.

Mitsubishi UFJ Financial
Group (MUFG)

Mitsubishi UFJ Trust andBanking Corporation (MUTB)* In order to comply with the regulatory requirements of the US Federal Reserve Board, FSI US has additional reporting requirements in to MUFG Fund Services (USA) LLC in the US.

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Principles of Internal Governance and Asset Stewardship 2024

Governance Arrangements
The diagram below illustrates our governance arrangements.

Board Governance
Board Committees of FSIH

Company Secretariat

Audit and Risk Committee
Reporting

FSI Subsidiary
Companies

People and Remuneration
Committee

ReportingConsultation

Independent Assurance and Advice
First Sentier Investors
Holdings Pty Limited(FSIH)

Recommendation

External Audit
Internal Audit

Accountability

Ownership and control

Delegation

Reporting

FSI Chief Executive Officer

Delegation

ReportingAccountability
Delegation

First Sentier Investors Executive
Leadership Team

Chief Risk
Officer

Accountability

Investment
Product
Research andAssurance(IRPA)

Global Headof Investment
Management

Accountability

Specialist
Responsible
Investment
Team

Chief Financial
and Strategy
Officer

CEO Delegated Management Committees
Global Risk Committee(GRC)

Global Investment Committee(GIC)

Accountability

Corporate
Sustainability
Team

Reporting

ESG Impacts Committee

RI/ESG Management Governance Forums

Global RI Executive Committee(GRIEC)

Reporting

ESG Regulatory Advisory
Group (ERAG)

Global Investment Committee

This committee meets quarterly and considers a wide range of matters
including: fund performance, risk parameters within and affecting the funds,
liquidity, responsible investments and ESG counterparty risk and investmentcompliance.

Global Risk Committee

This committee oversees the management of risks assumed by First Sentier
Investors in the course of carrying on its business, with particular focus on themeasurement, reporting and management of risks relevant to First Sentier
Investors.

Order Execution Committee

This committee is accountable for the oversight of the Order Execution Policy,
which includes trade execution and counterparty management.

Fair Valuation Committee

This committee determines the best estimate of the value, for part or all of
the underlying assets, of a Fund where reliable prices are not available at thevaluation point.

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Principles of Internal Governance and Asset Stewardship 2024

4.

Overview of the key management and investment
personnel within the organisation
Profiles of the key management personnel are available
on our website: https://www.firstsentierinvestors.com.
au/en/individual/who-we-are/management-team.html
Profiles of the key investment personnel are available
with their respective team profiles on our website:www.firstsentierinvestors.com.au

5.

How we ensure client assets are managed inaccordance with our investment strategies, and how
conflicts of interest are managed

Internal Governance
6.

First Sentier Investors has a Global Code of Conduct that outlines
how our people are expected to behave, and supports theprinciples governing conflicts of interest.
7.

– Employees must obtain prior approval from Compliance
before placing most personal securities transactions.

Compliance with our traditional investment strategies is overseenby the Global Investment Compliance team, with independent
investment assurance activities conducted by the Investment
Product Research and Assurance (IPRA) team. The Risk
Management, Compliance and IPRA teams report to the relevantboards and the committees.

The investment restrictions are then coded into the relevant
investment management systems so that pre- and post-tradecompliance can be undertaken. Investment restrictions are
regularly reviewed and audited against compliance documents.
Periodic reporting is provided to clients, along with theirportfolio information.
IPRA provides quantitative and qualitative assessments,
involving independent analysis to assess the risk and return
characteristics of the underlying portfolios and adherence
to the stated investment approach. Industry standard andmethodologies are utilised to investigate and report on a numberof investment risk and return characteristics, including evolving
standards relating to ESG and responsible investment. The
investment assurance activities are reported to the FSI Global
Investment Committee (GIC).
The GIC provides overall risk oversight and investment
assurance that our funds and mandates continue to be managed
in a manner that is consistent with the articulated investment
strategy and process. The committee meets on a quarterly basis.
Conflicts of interest are covered under point 8.

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Principles of Internal Governance and Asset Stewardship 2024

Personal trading

All FSI employees are subject to the First Sentier Investors
global personal dealing policy, which contains thefollowing requirements:

Compliance with investment strategies

All investment restrictions from the investment managementagreement, regulatory requirements and internal controls
where appropriate are incorporated into an internal compliancedocument for use by the portfolio managers, relationshipmanagers, risk and compliance personnel, and other selectedstakeholders. Sign-off by the relevant stakeholders is required toconfirm that the correct process has been undertaken.

Ethical conduct and professional practice– Additional restrictions apply to investment teammembers with funds management responsibilities.
– Black lists of securities are maintained. Approval totransact in a particular reportable security will be denied
if it is black-listed.
– There is a minimum holding period of 120 days.
8.

Management of conflicts of interest to ensureclient interests take priority (including gifts
and entertainment)

Our policy is to conduct all our business in an honest and ethicalmanner and we are committed to acting professionally, fairly
and with integrity in all our business dealings and relationships
wherever we operate. Conflicts of interest are managed inaccordance with our Global Conflicts of Interest Policy which
is summarised on our website and we also have a standalone
Global Gifts and Entertainment Policy.
https://www.firstsentierinvestors.com.au/content/dam/
web/australia/responsible-investment/au-conflicts-ofinterest-statement.pdf
9.

Risk management and compliance

The Risk Management Framework (RMF) provides a consistentand integrated approach to risk management that supports
First Sentier Investors business and strategic objectives, while
ensuring First Sentier Investors operates within its risk appetite
and in compliance with relevant laws, regulations and standards.
The RMF covers the systems, policies and processes that
identify and assess, evaluate, mitigate, monitor, and report on
all internal and external sources of material risks. These areconsidered in conjunction with the overarching RMS and RAS.

5.0 Stewardship
10. Trade Error Policies and Incident Management

12. Equitable asset valuation and pricing

First Sentier Investors has trade error policies which collectively
cover all fixed income and listed equity investment teams andhave the overarching imperative to correct errors as soon asreasonably practicable without harm or loss to clients.

The Northern Trust Company (NTRS) performs asset valuations,in accordance with a formal agreement as part of our outsourced
middle office services. In addition to this, State Street Australia
Limited perform asset valuations as part of unit pricing forinvestment funds we manage in Australia (amongst others).

When an incident is identified, it must be reported to Risk
Management through the global integrated risk management
system, Riskonnect. The root cause and impact of the incident
is assessed to determine the remedial and preventative actions
required. Risk Management independently review, approve, andmonitor an incident to closure. When a control weakness or gap
is identified, an issue will be raised in Riskonnect with defined
action plans and due dates to remediate the control weakness
or gap.
Regular incident and issue reporting is provided to senior
management, boards and committees.
11. Brokerage and commissions
Managing implementation costs (transaction and brokeragecosts, market impact costs and opportunity costs) is integral
to our investment processes. It is a discipline in which FSI has
a comparative advantage due to our size, various cash flows,investment in the latest trading technology, and the depth of
its in-house transaction expertise. Our experience in this area
enhances our ability to achieve best execution on behalf ofour clients.
In order to minimise our impact on securities prices, First
Sentier Investors uses an extensive network of brokerage firms
with contacts and expertise in various market segments. Our
approach takes into account security price, commission cost,
the nature of the order and other factors that are relevant to theinterests of the fund.
Our brokerage firms and commission rates are reviewed atleast annually. We are able to identify and separate between our
execution and third party research costs. In addition, all trades
undergo daily, independent, quantitative transaction cost analysis
to measure trade performance.

Outside of Australia, there are a number of Fund Administrators
supporting asset valuations within unit pricing in a similar way.
FSI applies a fair value pricing approach to asset valuations. FSl'sfair value pricing policy addresses the issue of determining avalue for those securities for which market prices are not readily
available. Generally, prices are considered readily available if
the exchange or market where the security trades is open andactively trading. Readily available prices will be obtained fromindependent industry standard vendors.
Where market prices are not readily available, such as in asignificant market event, a suspension, delisting or illiquidity, ourfair value pricing process requires our Fair Value Committee,
which is independent of the investment team, to consider suchfactors as recently dealt prices in similar instruments, broker
quotes and market proxies to determine a fair value. The Fair
Value Committee may also solicit a third party pricing vendor toprovide a fair valuation. All fair value decisions are documented
and retained.
13. Best execution and trade allocation
Each asset class has an approved broker list and from this list the
dealers undertake best execution.
We maintain a trade allocation policy that promotes honesty
and fairness for clients and investor allocations of the sameinvestment style and asset class. When our Portfolio Managers
submit orders for the same security across multiple portfolios,
our Dealing team may aggregate the orders into one trade toachieve the best outcome for clients. When this occurs, fills are
pro-rated back across all client portfolios to ensure fairness toall clients.
Remuneration policy
FSI has designed a Remuneration Policy to help us ensure that:• an appropriate employee remuneration framework exists to
support FSI’s vision, purpose and strategy;• our people are rewarded for role modelling our values anddesired behaviours;• our focus is on talent management and development,
attracting and motivating talented individuals, regardlessof gender, age, disability or any other factor unrelated toperformance or experience.

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Principles of Internal Governance and Asset Stewardship 2024

To achieve this objective, FSI’s remuneration strategy, principles
and framework sets out to competitively reward and motivate
our people to achieve individual and corporate performanceoutcomes that deliver long-term sustainable performance, to thebenefit of our stakeholders, including FSI’s clients, shareholder
and the communities within which we operate.
FSI’s Remuneration Framework adheres to all legal andregulatory requirements in each of the jurisdictions in which
FSI’s people are located, promotes sound and effective risk
management (including sustainability risks1 for investment
professionals) and will assist in avoiding or managing, as
appropriate, conflicts of interest.
Our remuneration framework forms part of a broader attraction
and retention strategy including benefits, culture, recognition,
performance feedback, development and organisational
purpose. It is delivered through a total reward package consistingof three key elements:
1.

Base Remuneration – set at market competitive levels
in line with the responsibilities of the role and individualcompetency requirements

2.

Variable Remuneration – for Investment Professionals thisincludes both short and long-term incentives to ensuresustainable long-term performance and stability of theinvestment team.

3.

Benefits – ensure market competitiveness and provide
benefits in accordance with local market practice. These areregionally based, including but not limited to, the provision ofsuperannuation/pensions, medical & life insurance, flexible
working arrangements, leave options, workplace culture,social committee/activities, volunteering opportunities,
community engagement and events, and learning anddevelopment opportunities.

FSI’s remuneration practices are designed to support equity,
diversity and inclusion within our workforce. Our principles enable
us to attract, motivate, retain, and reward employees regardlessof gender, ethnicity, age, sexuality, disability, religion, socioeconomic background or any other protected characteristic.
Variable Remuneration and Performance Risk Management:
Investment professionals are eligible to receive both Short-Term
Incentives (STI) and Long-Term Incentives (LTI):• STI is intended to drive and reward employee performancebased on achievement of portfolio performance benchmarks
over 1, 3 and 5 year performance, and adherence to FSI’svalues and risk management framework. Awards vary
to reflect performance achievement with meaningful
differentiation to recognise and reward strong contributors /performers. STI awards are paid in cash with some deferralto support sound risk management and meet regulatory
requirements.

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Principles of Internal Governance and Asset Stewardship 2024

• LTIs awarded to investment professionals are focusedon growth and value creation and sustained long-term
performance. Contribution to business objectives,
performance, behaviours and risk management are factorsthat may be considered when allocating LTI awards. Our LTI
structure is in the form of a profit-share scheme, whereby
LTI awards are delivered through co-investment instrumentsaligned to the underlying team funds which encourages
long-term alignment with clients’ interest. LTI awards are
subject to a three-year deferral period to aid retention andadherence to sound risk management practices and RI
principles as well as incentivises investment professionals toreinforce the team’s investment philosophies and processes,
which include assessing sustainability risks that may affectinvestment performance.
Performance is assessed not only on what is achieved over
the relevant performance period but importantly, on how it isachieved, as we believe the latter contributes to the long-termsustainability of the business. All employee performance iscarefully managed within FSI’s Risk Management Strategy("RMS”), and variable remuneration awards to individual
employees are reviewed and may be adjusted based on
associated performance and risk outcomes, the performance ofthe business unit and the performance of the business.
Performance and risk management is built into our remuneration
framework by ensuring that all employees are assessedagainst risk and behavioural standards, which are considered
upon allocation of short term and long-term incentives andagain upon vesting of deferred incentives to confirm they haveappropriately demonstrated our values. Further adjustments tovariable remuneration awards based on an individual employee’s
performance may include (but are not limited to):• Malus, such as reducing or forfeiting the incentive award,
including any unvested deferred award prior to the award
vesting; and/or• Claw-back, which would require an employee to repay on
demand an incentive award they have received.
For investment professionals, the implications of Sustainability(Environmental, Social and Governance related) Risk in
the investment process have been incorporated into theperformance framework.
This assessment ensures that variable remuneration awards
are based on both what was achieved (goals) and how it wasachieved (values), with adjustments for risk outcomes applied
where required. The values assessment includes adherence tothe firm’s RI and Stewardship Policies and Principles.

A$226.8

BillionIn assets managed on behalf of institutional investors,
pension funds, wholesale distributors, investment platforms,
and financial advisers and their clients worldwide*.

* Assets Under Management (AUM) includes all assets by FSI's investment teams and affiliates as at 30 June 2024.

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Principles of Internal Governance and Asset Stewardship 2024

14. Whistleblower protection policyFirst Sentier Investors is committed to maintaining highstandards of corporate governance ethics and behaviour.
Consequently, we require that our employees display thehighest levels of professionalism in all aspects of their work tofacilitate compliance with our Global Code of Conduct and allapplicable laws.
We encourage all current or past employees, as well as otherswith a connection to FSI such as current or past suppliers orservice providers and their employees or a relative or dependantor a spouse of any of these individuals who suspect misconduct
to Speak Up.
See the Whistleblower protection policy here:
https://www.firstsentierinvestors.com.au/au/en/individual/footer/whistleblower.html
Training and development
We are committed to the ongoing training and development ofour people, recognising that training and development comprises
a combination of experience, exposure and education.
All staff have mandatory training as part of the on-boarding
process, some of which are re-assessed annually. Within thefirst quarter of employment (typically within the first month), all
new staff are required to undertake a risk management andcompliance orientation session. Topics covered include Conflictsof Interest Policy, Personal Account Trading and Market Conduct.
Additionally, we have a specialised Global Mandatory Learning
curriculum. The curriculum is built around 7 identified coremodules we believe will assist our organisation to achieve ourobjectives, and is based on supporting all of us to increase
our capabilities across these areas and ultimately, achieve our
purpose, vision and strategy.

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Principles of Internal Governance and Asset Stewardship 2024

The global mandatory learning modules are as follows and must
be completed by all employees, upon commencement and on
an annual or bi-annual basis:• Financial Crime (including Anti-Money Laundering & Counter
Terrorism Financing, Sanctions, Anti-Bribery & Corruption
and Fraud)• Conflicts of Interest• Privacy and Data Protection• Market Conduct (including Personal Account Dealing)• IT Security• Acting with Integrity (including Ethics and Workplace Conduct)• Health, Safety & Wellbeing
Training is also organised for specific topics not covered bylearning modules, for example, Directors and Responsible
Officer’s duties under the Australian Services License
obligations. Relevant courses, seminars and conferences arealso considered as training as monitored and managed byindividual managers.
15. Complaints and dispute resolution
First Sentier Investors has a Global Complaints Handling Policythat provides the principles of complaints management which
is supplemented with local customer complaint handlingprocedures. Complaints are reported to the relevant Boards
and committees.
https://www.firstsentierinvestors.com.au/au/en/individual/footer/complaints-procedure.html
Wholesale and institutional investors can also contact theirrelationship manager to make a complaint.

Asset stewardship
16. Monitoring of company performance on financial andnon-financial matters
The integration of ESG factors into the investment process
is an integral component of our responsible investment
practices. Within FSI, there is not one standard approach to ESG
integration. For some investment teams it is achieved throughthe inclusion of an ESG score or rating to refine their investment
universe, for others it is integrated in fundamental research, inthe assessment of management quality or in valuation methods.
We supplement investment team analysis with external ESG
research from Sustainalytics, MSCI, ISS and Reprisk at firm level,
and a number of teams subscribe to additional data sets.
Each team’s approach to ESG integration is articulated in our
responsible investment and stewardship reports and is tailored
to its asset class and investment philosophy:
https://www.firstsentierinvestors.com.au/au/en/
institutional/responsible-investing/reports-andpolicies.html
The commitments our investment teams have made in relation tomonitoring company ESG performance are outlined in our Global
Responsible Investment and Stewardship Principles and Policy.
17.

Engagement with company management and theBoard (where appropriate), and escalation of issues ininstances where initial engagements have not beenadequately responded to

It is important that we engage in an active dialogue withall companies or entities that we invest in, as it provides
opportunities to improve our understanding of their businesses;monitor material business issues including strategy, capital
allocation, financials and ESG approach; and enables us to
influence them to improve these practices.
The breadth, depth and frequency of engagement will varysignificantly based on a variety of factors including the risks
and opportunities faced by the company, the opportunity andwillingness to engage by the company, and the size of nature of
the investment. Given the varying nature of the asset classes wemanage, the geographies in which they operate, and the size ofour holdings, each investment team's engagement approachis tailored to individual companies and the specific issues inquestion. There is a focus on material ESG issues that could
impact on investment value over all periods, but particularly overthe long term.
The commitments our investment teams have made in relation
to company engagement are outlined in our Global Responsible
Investment and Stewardship Principles and Policy, and asset
class specific considerations are outlined in the same document.

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Principles of Internal Governance and Asset Stewardship 2024

https://www.firstsentierinvestors.com.au/au/en/
individual/responsible-investing/reports-and-policies.
html
While each investment team has developed an approach
relevant to its own investment philosophy and asset class, ourclients can expect a shared commitment to engagement fromevery investment team.
Listed equities
Engagement with company management is a fundamental
part of our active equity teams' investment processes. Throughcompany engagement, we seek to highlight areas for potential
improvement and risk reduction, encourage improved disclosure
on ESG issues, and commend companies that are making
progress in these areas. On occasions where our engagement
activities are unsuccessful and we believe that this will remain so,
we may escalate the issue. For example, we may write to, or meetwith the chairperson or lead independent director. We may voteagainst directors who we believe are not providing appropriate
oversight, or we might collaborate on further engagement withother like-minded investors. In some instances, we may makeour views public.
Ultimately, where we lose confidence in management, following
unsuccessful attempts to engage, we may sell down our holding.
Fixed income
In addition to engagement with companies, fixed income andcredit teams have opportunities to engage with counterparties,
credit rating agencies, government, semi-government andsupra-national issuers. Fixed income investors should be
proactive in engaging with those parties who can influence longterm investment outcomes. We provide a number of case studiesof this engagement in our annual Responsible Investment report.
https://www.firstsentierinvestors.com.au/au/en/
individual/responsible-investing/case-studies.html

Unlisted infrastructure

Listed equities

For unlisted infrastructure assets, our seats on company boards
allow direct oversight and influence. The unlisted infrastructure
team, Igneo Infrastructure Partners, has a dedicated approach
which is available on its website:

Each active listed equities team has a process for identifying
and assessing the relevance and materiality of ESG issues
for their respective asset classes. For all active equity teams,
company engagement is a key source of insights on such risks
and opportunities.

https://www.igneoip.com/australia/en/institutional/
responsible-investing-approach.html
18. Approach to considering environmental, social andgovernance factors (risks and opportunities); whether
these considerations influence investment decisionmaking and company engagement
The individual approaches to ESG integration taken by eachteam are available in our annual Responsible Investment and
Stewardship Reports:
https://www.firstsentierinvestors.com.au/au/en/
individual/responsible-investing/reports-and-policies.
html
The common elements of these approaches are outlined in
our Global Responsible Investment and Stewardship Principles
and Policy.
A key part of our approach to RI includes commitments to:support and uphold fundamental principles of human rights,
support international norms and standards enshrined in widelyadopted treaties, conventions and codes of practice; and upholdthe highest standards of environmental stewardship.
Exceptionally, where a company's activities conflict with thesecommitments, we may implement a company-wide ban on
investment (in both equity and debt) in certain sectors orcompanies. Such a decision is taken by the GRIEC taking
into account the factors outlined above, together with our
fiduciary duty, client sentiment and long-term sustainability andinvestment risk.
Currently, we exclude companies that manufacture cluster
munitions, antipersonnel mines, cigarettes and tobacco
products, and companies and countries on various sanctions
lists. Information on our approach to ESG-related exclusions isavailable in our Global Responsible Investment and Stewardship
Principles and Policy.
While each team has developed its own approach relevant to its
investment philosophy and asset class, our clients can expect
the following from all our investment teams.

Some teams assign specific ESG scores, while others
incorporate the assessment into broader views of company
management and business quality. All active equity teams holdregular team meetings to discuss company assessments,
including ESG factors.
Fixed income
Like our equity teams, our fixed incomes teams have developed
their own approaches to ESG integration that complement
their investment processes. All teams within our global fixedincome business share significant elements of their investment
processes, including analyst resources and our global
Investment Opinions Network platform.
All our teams believe the ESG issues have a direct impact on
an issuer's risk, and therefore its probability of default. As risks
turn into liabilities, they can impact cash flow and, therefore, debt
costs and credit ratings.
Unlisted infrastructure
For our unlisted infrastructure team, Igneo Infrastructure Partners,
the ownership interest we hold in portfolio companies ranges
from approximately 15% to 100%. Our investment professionals
are therefore a key part of the corporate governance structure
and often sit on governance and management committees, suchas boards of directors or shareholder representatives groups.
Consequently, a more bespoke approach to ESG integration isdesirable and necessary. The team has developed separate
and detailed RI policies and assessment frameworks, while still
adhering to the organisation-wide approach.
Igneo Infrastructure Partners prefers to take a lead role in any
acquisition and lead the agenda in the consideration of all
investment issues, including ESG. Further, in instances where we
do not acquire a controlling interest, we make sure we carefully
select like-minded co-investors. That ensures we have a similar
approach to all investment issues, including ESG considerations,defining strategy and approving policies.
Once appointed, our directors oversee executive management,
influence business strategy and embed operational andinvestment policies - including consideration of ESG issues.
These insights, coupled with the best available third party ESG
research, are assessed by the relevant company analyst andincorporated into stock notes or reviews. These insights influencecompany valuations.

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Principles of Internal Governance and Asset Stewardship 2024

Glossary
19. Proxy voting (see FSC Standard 13)
Proxy voting rights are an important asset for listed equity
investors and exercising these rights is a core part of ourstewardship responsibilities. We seek to vote on every resolution
at company meetings where the client has delegated voting
rights to FSI.
Prior to voting, the relevant investment manager and analyst
carefully consider each resolution, with guidance provided in
our Global Responsible Investment and Stewardship Principles
and Policy. Recommendations from a selection of independent
corporate governance research providers are also sought.
We use the corporate governance analysis and recommendation
services of Glass Lewis and Ownership Matters and additional
corporate governance information from MSCI, Sustainalytics,
brokers and other sources.
Proxy voting service providers are selected on the basis of thequality of their research and the extent of their coverage. We havebeen using Glass Lewis and Ownership Matters, and review theirperformance periodically.
Our investment teams retain full control over their proxy voting
decisions, however, and do not necessarily follow the guidance
provided by third party governance research providers. Our
website provides a proxy voting tool which discloses all voting
decisions all voting decisions post-meeting.
https://www.firstsentierinvestors.com.au/au/en/
individual/responsible-investing/proxy-voting.html
All teams have an approval and escalation process for proxyvotes. They maintain records that show when they vote against
management. Investment teams are responsible for their own
voting and, from time to time, different teams may vote in different
ways on the same issue.

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Principles of Internal Governance and Asset Stewardship 2024

20. Collaborative engagement with other investors,
including involvement with industry groups
and associations
Much of our engagement is conducted by each team directlywith companies, however, we also engage with companies
alongside other investors as part of an industry group, or througha letter or other group engagement work.
We take a leadership role on collaborative initiatives and working
groups that meet these requirements and seek to align ourselveswith organisations that share our values in relation to RI andbeing a responsible business. We recognise that we will achieve
far greater impact on systemic risks when we work together withother investors and service providers.
We provide support to a number of industry groups who areseeking to grow and improve responsible investment andstewardship practices. We review the work, philosophy andadvocacy of the organisation of which we are members regularly
and seek to positively contribute to their work agenda throughparticipation in governance positions and working groups. While
we support the work and we are proud of our association withthese groups, they do not represent our views except where wesign specific statements. The industry groups we are currently
active members of are listed below:

Industry collaboration

Each year, we review the various initiatives that we have been
involved in. We do this to ensure their purpose aligns withour clients’ interests and that we have the capacity to make ameaningful contribution. The initiatives that we actively supportand engage with are listed here:
GlobalAsia Pacific

30% Club Australia (2018)• Investor Working Group Member
40:40 Vision (2020)• Steering Group Member• Investor Working Group Member

Cambridge University’s Investment Leaders Group (2013)

Australian Sustainable Finance Initiative (2022)• Nature working group member• Director of the FSC Board• Founder Member

Financial Services Council (2020)

Climate Action 100+ (2017)• Member of the Fund Management Board Committee

Finance for Biodiversity pledge (2021)• Member of the ESG Working Group

Nature Action 100 (2023)• Member• Supporting Investor• Signatory• Member of the Investment Expert Group
Hong Kong Green Finance Association (2023)• Investor Participant, member of engagement team with
one company

Investors Against Slavery and Trafficking APAC (2019)

Net Zero Asset Managers initiative (2022)

Investor Group on Climate Change (2013)• Member• Advisory Group Member
Principles for Responsible Investment (PRI) (2007)• Signatory• Pilot sovereign engagement, member (2023)• Spring (PRI’s stewardship initiative on nature) endorser (2023)
Tobacco Free Portfolios Pledge (2021)• Signatory and Pledge Stamp Member
Task Force on Climate-Related Financial Disclosures (2021)• Supporter

Taskforce on Nature-related Financial Disclosure (2022)• Forum member• Chair• MemberJapan Sustainable Investment Forum (JSIF) (2021)• Signatory

Japan Stewardship Initiative (JSI) (2021)• Signatory

Responsible Investment Association Australasia (2013)• Board Member• Member of the Nature Working Group• Member of the Human Rights Working Group
Women in Sustainable Finance (2019)• Committee Member
EMEA
EUROSIF* (2013)• Public Policy Working Group* Only national SIFs are members of EUROSIF. FSI participate in EUROSIF monthly
Public Policy Group as a guest/non-member.

FAIRR (2023)• Investment member
Irish Funds Association• ESG Data Reporting Working GroupUK Sustainable Investment Forum (2013)• MemberWorld Benchmarking Alliance (2023)• Ally15

Principles of Internal Governance and Asset Stewardship 2024

21. Principles used for policy advocacy, including
participation with industry groups and associations

22. The approach to client engagement, education andcommunication regarding asset stewardship.

We believe that it is our responsibility to engage in public policy
debates and industry initiatives on RI topics, in line with ourclients' interests and where we have relevant experience. Issues
we will seek to engage and collaborate on include:

The ability to deliver sustainable long-term investment
performance relies on understanding the needs and meeting the
expectations of our clients.

– Development of markets– Quality of markets– Understanding of ESG factors as sources of risk
and return– Enhancing our clients' interests and awareness of
ESG issues– Policy and regulatory developments– Implementation of standards for company reporting onmaterial ESG issues
Our Global Responsible Investment and Stewardship Principles
and Policy documents outline our philosophy in this regard.
Our position on policy advocacy in relation to climate change isoutlined in our Ciimate Change Action Plan, which is available on
our website:
https://www.firstsentierinvestors.com.au/au/en/
individual/responsible-investing/reports-and-policies.
html
We are strong advocates for responsible investment andstewardship and for more sustainable capital markets.
We believe this is in the best long-term interests of our clients.

16

Principles of Internal Governance and Asset Stewardship 2024

We publish annual Responsible Investment and Stewardship
Reports. These reports include individual investment teamprofiles with detailed information about their approach tostewardship and ESG integration, and ESG risk profiles of theirfunds and portfolio-level carbon data. Our website also presents
over 130 case studies, and provides up-to-date proxy voting
information and updates on our responsible investment strategy.
A number of our investment teams produce team-level quarterly,
biannual or annual RI reports.
Additional client communications are tailored to regional needs
with client feedback allowing us to create bespoke solutions. For
some clients we provide additional reporting as part investment
management agreements. We are constantly looking for ways toprovide better and more informative reporting to our clients.

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Sentier Investors, a global asset management business. First Sentier Investors is ultimately owned by Mitsubishi UFJ Financial Group, Inc (MUFG), a global financialgroup. References to “we” or “us” are references to First Sentier Investors. Some of our investment teams use the trading names FSSA Investment Managers,
Stewart Investors and RQI Investors. A copy of the Financial Services Guide for FSI AIM is available from First Sentier Investors on its website.
Any advice in this material is general advice only. It does not take into account your objectives, financial situation or needs. Before making an investment decision
you should consider, with a financial advisor, whether this information is appropriate in light of your investment needs, objectives and financial situation.
Any opinions expressed in this material are the opinions of the individual author at the time of publication only and are subject to change without notice. Such
opinions: (i) are not a recommendation to hold, purchase or sell a particular financial product; (ii) may not include all of the information needed to make an
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We have taken reasonable care to ensure that this material is accurate, current, complete and fit for its intended purpose and audience as at the date of
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