SUSTAINABILITY ACCOUNTINGSTANDARDS BOARD (SASB)DISCLOSURE

Financial Year 2022
Data as at 30th June 2022

Asset Management & Custody Activities
Hargreaves Lansdown plc is reporting under the SASB disclosure framework for the FY22 period ending 30 June 2022. In
this report we have responded to the reporting standards for Asset Management & Custody Activities. The SASB
disclosure framework is a key reporting standard which aligns with our business and investor needs, we will continue toiterate our reporting process and will take a proactive approach to any updates issued by SASB moving forward.

All figures are for Financial Year 2022
2022 (as at 30th June
June 2022
2022)
Accounting Metric

Code

Disclosure/ Source

Transparent Information & Fair Advice for Customers(1) Number and (2) percentage of covered
employees with a record of investmentinvestmentrelated investigations, consumerconsumer-initiatedcomplaints, private civil litigations, or otherregulatory proceedings

FN-AC-270a.1

Of Hargreaves Lansdown’s 2,042 employees, there were 2 (0.1%)
recorded instances where an employee had a disclosed event. Both ofthese employees have since left Hargreaves Lansdown employment.

Total amount of monetary losses as aresult of legal proceedings associated withmarketingmarketing and communication of financial
product related information to new andreturning customers

FN-AC-270a.2£0Hargreaves Lansdown did not suffer any losses as a result of legal
proceedings associated with the marketing and communication offinancial products in the Financial Year 2022.

Description of approach to informing
customers about products and services

FN-AC-270a.3

Our approach to informing clients about our products and services isessential for building trust and deepening our client relationships.
Please see Appendix A to better understand our approach.

FN-AC-330a.1

Hargreaves Lansdown is committed to building a diverse and inclusive
workforce, not simply because it is the right thing to do, but because
we believe it will lead to better outcomes for clients, colleagues, ourbusiness and enable our sustainable growth. The more diverse ourpeople, the more easily we can understand and meet the needs of our
growing and increasingly diverse client base.

As per SASB, a disclosed event includes investment related
investigations, consumer-initiated complaints, private civil litigations,or other regulatory procedures.

Employee Diversity & Inclusion
Percentage of gender and racial/ethnic
group representation for (1) executive
management, (2) nonnon-executive
management, (3) professionals, and (4) allother employees

Our Inclusion and Diversity strategy focuses on four pillars:• Building an inclusive culture and brand• Recruitment and representation• Progression and retention• Reporting and accountability.
Each pillar is supported by a detailed action plan to ensure we attract,hire, progress, engage and retain diverse talent and build a marketleading culture.
Please see Appendix B for our diversity figures for FY22.
To discover more about our Inclusion and Diversity work, please see
our Corporate Social Responsibility and About Us sections of the HL
website. To better understand our Board Diversity policy, please see
here.
Alternatively, please refer to pages 27-29 and 82 of our 2022 Annual
Report & Accounts

Incorporation of Environmental, Social, and Governance Factors in Investment Management & Advisory2

Amount of assets under management, byasset class, that employ (1) integration ofenvironmental, social, and governance(ESG) issues, (2) sustainability themed
investing, and (3) screening

FN-AC-410a.1(1) Environmental, Social and Governance (ESG) factors are
considered in all our research and investment processes which
underpin our investment decision making. Hargreaves Lansdown
Fund Management (HLFM) considers material ESG factors in all
the investment processes covering both the HL Multi Manager
and HL Select fund ranges, although they do not currently run any
explicit Responsible Investment mandates. HLFM signed up to
the UN-backed Principles for Responsible Investment (PRI) in
May 2021.
(2) 0(3) From October 2022 our HL Select funds and segregatedmandates held within the HL Multi-Manager range exclude
companies involved in controversial weapons (anti-personnel
mines, cluster munitions and chemical & biological weapons),
companies that make 20% or more of their revenues from oilsands extraction or thermal coal extraction and/or power
generation from thermal coal, and companies in breach of the UN
Global Compact for a continuous period of three years or more.
See our ESG Investment Policy for more details on our
exclusions.

Description of approach to incorporationof environmental, social, and governance(ESG) factors in investment and/or wealthmanagement processes and strategies
strategies

FN-AC-410a.2

Hargreaves Lansdown incorporates material ESG factors into theinvestment process and investment decisions within all the HL MultiManager funds and HL Select funds. Our investment teams haveaccess to a wide range of resources and data allowing them toconsider and research ESG in the investment process throughproprietary systems and external providers such as Bloomberg,
Morningstar Direct and Sustainalytics.
Our Multi Manager investment teams frequently engage with fundmanagers to determine whether the manager is both aware of andtaking seriously the ESG-related risks that may impact their portfolio
and are supported to do so by the fund house they work for.
All of the fund groups we invest up with must be signed up to the
Principles for Responsible Investment, or their country equivalentcommitment to responsible investment, and make a public pledge toachieve net zero by at least 2050 (across at least their scope 1 and 2
emissions). They must also be working towards creating a robusttransition plan to support this pledge. Those that have not set a
decarbonisation target will face divestment after a two-year
engagement period should they not comply.
Our HL Select fund managers approach ESG within a proprietary
research framework that assesses and evaluates the risks andopportunities linked to the ESG characteristics of each company they
invest in. This allows for a holistic view of material ESG factors before
deciding which companies to invest in.
Across all portfolios over which we have discretion (including the HL
Select funds and segregated mandates held within the HL MultiManager range), companies involved in controversial weapons (antipersonnel mines, cluster munitions and chemical & biologicalweapons) are excluded. We also exclude companies that make 20% ormore of their revenues from oil sands extraction or thermal coal
extraction and/or power generation from thermal coal, andcompanies in breach of the UN Global Compact for a continuous
period of three years or more.
To understand more about our approach to integrating ESG within ourinvestment decision making processes, please read our ESG
Investment Policy.

Description of proxy voting and investee
engagement policies and procedures

FN-AC-410a.3

Within our HL Select funds, we utilise the services of Institutional
Shareholder Service (ISS), a company with a long track record ofmonitoring and advising upon corporate governance best practice.

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HLFM will exercise their voting rights in a timely manner with the aim toachieve the best possible client outcome.
Within our Multi-Manager funds, we delegate voting responsibility to
the underlying fund managers.
To find out more about our proxy voting process, please see our
Stewardship and Engagement Policy.
Additionally, please see our Engagement Report for further insights.

Business Ethics
Total amount of monetary losses as aresult of legal proceedings associated withfraud, insider trading, antianti-trust, antianticompetitive behaviour, market
manipulation, malpractice, or other related
financial industry laws or regulations

FN-AC-510a.1£0Hargreaves Lansdown has not sustained any monetary losses as aresult of legal proceedings associated with fraud, insider trading, antitrust, anti-competitive behaviour, market manipulation, malpractice,or other related financial industry laws or regulations.
Hargreaves Lansdown require all colleagues to undergo annual
training surrounding regulatory matters including but not limited to
CASS, Data Protection, Market Abuse, Fraud Prevention,
Whistleblowing, Anti-Bribery and Corruption. Hargreaves Lansdown
expect all colleagues to hold themselves to the highest standards of
ethics and encourages employees to undertake frequent
recommended training on areas of importance to the role.

Description of whistle blower policies andprocedures

FN-AC-510a.2

Hargreaves Lansdown promotes a safe and honest culture which
encourages employees to raise any malpractice concerns such as asuspected employee fraud, a bribery & corruption issue, a danger tohealth and safety, or the concealment of rule breaches.
The whistleblowing policy applies to all those who work for us,
including:
All colleagues, full time, or part time
Contractors and subcontractors
Agency colleagues
Colleagues can raise concerns to our:Head of Market Abuse and AML Regulatory Change
Compliance Director
Six additional senior managers who act as ‘Speak Up’guardians
Alternatively, all colleagues can receive confidential advice on a matter
through an external Independent Charity at whistle@protectadvice.org.uk
For more information, please see our whistleblowing policy

Activity Metric

Code

Disclosure/ Source(1) Total registered and (2) total
unregistered assets under management(AUM)

FN-AC-000.A

Hargreaves Lansdown’s AUM comprises of registered andunregistered AUM. Registered AUM include those subject to theregulations of the Investment Company Act of 1940 (1940 Act), suchas mutual funds, managed under the Employee Retirement Income
Security Act of 1974 (ERISA), subject to the Undertakings forCollective Investment in Transferable Securities (UCITS) Directive, ormanaged under the Commodity Futures Trading Commission’s(CFTC’s) Commodity Pool Operator (CPO) regulations. Unregistered
AUM are those that do not fall under the definition of the registered
AUM.
Registered AUM
Unregistered AUM

4£0.98 billion£6.99 billion

TotalTotal assets under custody andsupervision

FN-AC-000.B£7.97 billion£7.97 billion

Appendix A
FNFN-ACAC-270a.3
Description of approach to informing customers about products and services
Hargreaves Lansdown is a publicly traded wealth management company offering a wide range of products and services throughinvestments, savings, pensions, and advice to both retail and institutional clients.
Our website, www.hl.co.uk, provides comprehensive direct-to-client investment services. It hosts a wide range of factual and option-based
information on savings and investments, including product and services offered by Hargreaves Lansdown. It also hosts a wealth of insight,
tools, guides and other education all designed to help people make better decisions with their money and to empower people to save andinvest with confidence.
Types and frequency of communication
We communicate with our clients using a range of different methods depending on the client’s preferred channel and the information being
communicated. Clients will receive all notifications and information required during their time as a client, including but not limited to contract
notes for any purchases and sales, quarterly investment reports and, if applicable, an annual tax certificate. In addition, we will notify clientsof any corporate actions taking place to any of their investments held with Hargreaves Lansdown, this will include but is not limited to rights
issues, consolidations, bonus issues or name changes. We also respond to requests by our clients for ad hoc information related to activity
in their account.
ValueValue-added communications
communications
Hargreaves Lansdown build investor engagement and drive better client behaviours and outcomes. We do this by providing clients andpotential investors with value-added expert tools, guides, insights and research through various media and channels.
We know investors trust and value our insight and opinion – not only our clients, but those of other platforms who use our free, open
information. We work tirelessly to find new ways to improve the information we provide investors, and drive better client outcomes,
stepping in where we see poor client behaviours or to add reassurance during periods of market volatility.
Our Better Investors campaign is a prime example of how we lead the investment industry in putting client outcomes first. Our campaign
targets clients with information and behavioural nudges to educate and help them make better decisions. The communications focus onproviding relevant information that helps clients to target their investment choices around their goals, raise awareness of how changing
conditions suit different investments and how they can build long-term savings. Alongside this we continue to engage with regulators,
working on how we can continue to serve our clients better, deliver the right outcomes and continue to set an example as the market
leading service in our industry.
Our deep understanding of clients, with vast insight on what they want to know – and how they’re using our platform – helps us identify key
trends in investor interest. An example being the change in retail investor interest in ESG. We can then respond to these changes in interestby making more online resources and information available.
Another example of this dynamic approach to content includes our drive to support the nation in building financial resilience, through our 5
to thrive campaign. Here we provide articles and insight on the 5 key building blocks for financial resilience; Control your Debt, Protect you
and your family, Save a penny for a rainy day, Plan for later life, Invest to make more of your money.
Switch Your Money ON is our fortnightly podcast launched in July 2021. The hosts are joined by guests from the HL investment researchteam, external fund managers and sector experts to deliver topical and news-based investment content in an entertaining way. It targets
engagement from younger, often app-first, audiences and aims to encourage them to be better investors.
Whilst most of our content is online, we cannot ignore those who prefer to engage and digest information and content through other media
and channels. We’re one of the few direct-to-client investment platforms with a regular investment magazine, the Investment Times. It is aquarterly print and online investment magazine that explores an overarching theme or trend in detail. Print editions use sustainable
resources and are now sent in recyclable paper envelopes rather than degradable plastic, saving the equivalent of 1.4 million plastic bags perannum.
We are also driving better accessibility and inclusivity across our website content and our communications to investors. We work to makeour websites accessible and follow guidelines laid down by the Web Accessibility Initiative (WAI). Our aim is to conform to Level AA against

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Web Content Accessibility Guidelines 2.1 (WCAG) standards. Hargreaves Lansdown has Accessibility Ambassadors sitting within teams
across the business, focused on driving better awareness and education for those creating content and communications. We deliver ourservice in a way that is accessible to all clients. We have a partnership with Dementia UK to ensure that we can support vulnerable clients andtrain colleagues to ensure we are providing the best service for our clients.
We continue to challenge ourselves to deliver a better experience for our clients through the information and communications we provide.
We will make greater use of data analytics to deliver more tailored content to engage with clients and we’ll increase our focus on making
clients better investors.
Communications Principles and protocols
While communicating with clients about our products and services, Hargreaves Lansdown abide by various regulations set out in the FCA’s
product governance sourcebook (PROD 3), as well as internal policies and frameworks requiring our communications to be appropriate to
the client audience, fair and transparent and aimed at producing the best possible client outcome.
Our clients range from first time investors to the highly experienced, with different levels of confidence, time and willingness to engage with
their finances. As such, our content and communications must suit their varying needs and appeal to anyone who wants to engage in saving
and investing.
Our Product Governance Committee overseas the implementation of our internal communications framework, chaired by the Director of
Investments and Retirement, to ensure Hargreaves Lansdown meet the legal and regulatory obligations required during communications.
How we communicate with our clients is as important as the information we provide. Industry jargon and lack of clarity can prevent peoplesaving and investing with confidence. Our content and communications are written in a way that aims to break down the barriers and makeinvesting accessible to a wider audience. Our authors have the subject, product or service expertise and knowledge to share information in away people can easily understand, allowing clients to take next steps confidently.
We use both quantitative and qualitative research to monitor the quality of our online content, making use of website analysis and tracking
tools and by seeking feedback from our clients using a content scoring system and client surveys. This information is reported to content
and communication authors on a regular basis and the continuous feedback loop is key to us ensuring that we continue providing thecontent our audience want and need.

Appendix B
FNFN-ACAC-330a.1
non--executive management, (3)Percentage of gender and racial/ethnic group representation for (1) executive management, (2) non
professionals, and (4) all other employees

In the below we have broken our colleague population down into the following categories based on our internal definitions tohighlight the above % breakdown:-

Board of Directors (broken out for gender breakdown) – 8 non-executives and 2 executive management – covers (1)and (2)Other Senior Management – Remaining executive management and direct report senior managers – covers (1), (2)and (3)
Total Employees – covers (4)Ethnic Breakdown as at 30th June 2022:

Total UK Workforce 2,042
Other senior management
Number
Asian
Black
Mixed
Other
White
Prefer Not to Say/ Unknown

0
0
1
0
38
8

%
0%
0%
2%
0%
81%
17%

Total employees
Number
91
44
56
10
1527
314

%
4%
2%
3%
0%
75%
15%

*Excluding employees located in Poland.
The HL plc Board met the Parker Review recommendation to have at least one director from an ethnic minority background by 2021.

6

Gender Breakdown as at 30th June 2022:

Total UK Workforce 2,042
2,042
Board of Directors
NumberFemaleMale

5
5

Other senior management

%
50%
50%

Number

%

13
34

28%
72%

*Excluding employees located in Poland

7

Total employees
Number
839
1,203

%
41%
59%