INVESTMENTSTEWARDSHIPREPORT
2023

Contents
A letter from our President and Chief Investment Officer
2023 milestones and highlights
What comes next – looking ahead
1. Russell Investments – Who we are
1.1 Our purpose
1.2 Culture
1.3 Values
1.4 Investment philosophy
1.5 Our responsible investing framework
1.6 Our history of innovation

2. Russell Investments – Who we are
2.1 Our clients and assets under management
2.2 Client communications
2.3 Client training and development
2.4 Taking account of client preferences
2.5 Climate aware solutions
2.6 Addressing client needs in practice

3. Governance of stewardship
3.1 Global governance structure
3.2 Investment governance structure
3.3 Responsible investing governance structure
3.4 Resourcing stewardship
3.5 Alignment of incentives to integrate stewardship

4. ESG Integration and Responsible Investing
4.1 Our integrated approach to stewardship and investment
4.2 Our risk management program
4.3 Addressing market-wide and systemic risks: climate change
4.4 Our approach to monitoring service providers

5. Active Ownership
5.1 Our engagement approach
5.2 Proxy voting

6. Policies, processes, and procedures supporting responsible investing
6.1 Our integrated approach to stewardship and investment
6.2 Diversity and inclusion
6.3 Policy advocacy and collaborations
6.4 Reviewing policies and processes

7. Appendix: Stewardship code mappings
7.1 The UK Stewardship Code
7.2 Japan Principles for Responsible Institutional Investors
7.3 The New Zealand Stewardship Code

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A letter from our President andChief Investment Officer
Last year was yet another chapter in the ongoing narrative that the 2020s will be a historic decade defined by inflation, global
conflict, climate events, market volatility and uncertainty. The trajectory of 2024 is set to follow suit, with pivotal elections
involving half the world’s population.
While disruption brings its own set of challenges, it also paves the way for innovation and shifts in the investment landscape.
Artificial intelligence, once a sci-fi notion, now revolutionizes our decision-making processes. The advent of remote work anddigital economies has transformed business models, sparking unparalleled innovation and growth.
At Russell Investments, we’ve navigated 88 years of profound change. We don’t just recognize change - we anticipate it, aligning
our strategies with our clients’ evolving aspirations. Our commitment to informed decision-making, which incorporates new
sources of information and data, is driven by our belief that responsible investing and good stewardship are integral to achieving
our clients’ aspirations. This dedication serves a singular goal: enhancing investment outcomes.
Given our scale and multi-manager platform, we have a differentiated dataset that can help drive the solutions our clients arelooking for across themes such as climate and sustainability. As a signatory to the principles for responsible investing since2009, our investment approach has been informed by thoughtful consideration of sustainability-related risks and opportunities
rooted in financial materiality and fiduciary duty. This approach is supported by a robust stewardship strategy and an integrated
active ownership program. As the world considers how to transition to a more sustainable economy, we believe this is more
important than ever.
At COP28, global leaders reaffirmed their commitment to urgent climate action, highlighting the imperative of collaboration andinnovation to mitigate the effects of climate change with an agreement signaling the “beginning of the end” of the fossil fuel era.
We firmly believe that by enhancing our climate investing capabilities, we can better manage our risks, uncover new investment
opportunities, and enhance the resilience of our portfolios. In order to meet client goals and expectations, we persistently refine
our practices, expand our toolkit, and enhance our reporting capabilities. For example, in 2023 we refined our process forevaluating private markets managers, launched a Net Zero Dashboard to support funds which have net zero targets, andexpanded the metrics available on our portfolio management platform.
Our innovation is equally evident in our solutions design. In 2023, we launched bespoke active equity strategy consisting of adiversified set of best-in-class managers that stand to gain from and contribute to the transition economy. Additionally, we haveintroduced a newly launched global unlisted infrastructure fund, which invests in assets providing essential services to enable,
sustain or enhance economic activity and standards of living, producing quantifiable sustainable outcomes.
More details on our responsible investing practices and client-centered approach are contained in this 2023 report. This reporthas been elaborated by the range of responsible investing experts embedded throughout our organization and reviewed andapproved by me, as President and Chief Investment Officer, as well as the Board of our UK entities. We welcome your feedback
and questions.

Kate El-Hillow
President and Chief Investment Officer, Russell Investments

Russell Investments / Investment Stewardship Report/32023 milestones and highlights

Data as of December 31, 2023.

Russell Investments / Investment Stewardship Report/4What comes next – looking ahead

As committed stewards of our clients’ capital, we continue to advance our responsible investing capabilities; integrating andevolving best practices to respond to changing market conditions. Our strategies are developed by experienced practitioners inalignment with our larger purpose of improving financial security for clients. The key pillars of our approach include:

Sustainable solutions
Evolving and developing new investment solutions is fundamental to our focus on meeting our clients’ needs. We leverageinnovation and industry leading insight to set total portfolio-level direction that aligns to targeted financial and sustainableoutcomes.
In 2023, we launched bespoke and commingled strategies, targeting both listed and private markets, with a range of sustainable
and carbon-related goals, and we have laid the groundwork for additional solutions in 2024. Our sustainable multi-manager
solutions will continue to leverage our market-leading overlay capabilities, while moving beyond carbon-focused metrics toinclude forward-looking sustainability projections. In addition, we developed our sustainable transition stock universe and havebegun work on evolving our decarbonization strategies to meet the rapidly evolving needs of our clients and the broader
industry. These efforts support our global solutions platform and underpin our ability to customize and deliver tailored outcomesfor clients.

ESG Integration
We have put meaningful resources into improving the data and analytics available to our portfolio managers who seek to monitor
and manage material long-term risks. Among our achievements: streamlining the transmission of ideas and information from
portfolio management to active ownership and using improved data and scenarios on climate risk to enhance our asset allocation
capabilities. We expect the use of data and the development of analytical tools to continue in 2024.
To deliver planned multi-manager funds with sustainable objectives, our analysts continue to expand our list of recommended
products within our sustainable manager research universe. While investment opportunities remain narrow, we are closely
monitoring emerging themes such as natural capital efficiency and biodiversity.
Our work to strengthen responsible investing practices in fixed income, real assets, private markets, and alternatives also
remains a priority. In 2023, we focused on strengthening our approach to sustainability risk management and active ownershipin fixed income while in private markets we capture the benefit of heightened ESG-related due diligence. In 2024, we willcontinue to push for greater transparency and disclosures from our managers, particularly with regard to sustainability risks andstewardship activity.

Climate risk management
Climate risk management remains an evolving area in financial markets. We are committed to working in collaboration withother leading industry participants to formulate best practice principles and frameworks. In 2024, we will continue to leverage
our partnership with a specialist climate risk provider, adding incremental climate risk metrics into our investment practice andextending our collaboration with industry peers. In addition, we intend to expand our climate risk research to cover additional
asset classes. We will continue to provide training to our associates to keep them abreast of complex and emerging concepts andsystems related to climate risk management. Similarly, we will maintain outreach, consulting services, and education on climate
risk for our clients.

Active ownership
In 2024, our current three-year active ownership strategy cycle will conclude. We aim to review the results achieved by ourprogram and update our approach to better align with market trends, client objectives, and ambitions. As part of this review, we
will closely examine our collaborative efforts and policy advocacy activities to amplify the impact of our active ownership efforts.
Additionally, in 2024, we will start our active participation in Nature Action 100, aiming to contribute to the transition towards amore sustainable and resilient global economy.

Russell Investments / Investment Stewardship Report/5Transparency and reportingAs reported in last year’s submission, our Enterprise Risk Management System (‘ERMS’) risk engine is now in use across all ourportfolios, enabling total solution analysis for clients, supporting crosscutting multi-lens risk analysis which encompasses multiasset combinations. We will continue to enhance this dataset and analytic competence to improve client reporting across theboard including, but not limited to, ESG metrics and objectives. We can report that enhancing client transparency is wellunderway with more expected over the course of 2024.
While ESG data and metrics have improved considerably in recent years, we believe that gaps still exist. Continued
enhancements will contribute to helping clients further understand our stewardship efforts, as well as the risks and opportunities
within their mandates.

Training and development
To stay at the forefront of sustainable investing, Russell Investments has provided training and development on ESG matters toboth clients and internal associates.
We have made training available to our clients through webinars, conferences, and whitepapers, enabling them to understandthe significance of ESG factors in investment decisions. We have also greatly enhanced the internal training provided to ourassociates. We have developed a comprehensive ESG curriculum that covers foundational ESG principles, analysis, andintegration into investment processes. We are fully committed to continuous enhancements and updates of our training. We
believe that by providing comprehensive education to both clients and associates, we can continue to meet the changing needsof our clients, enhance our investment processes, and maintain our position as a leader in the investment industry.

Russell Investments / Investment Stewardship Report/61. Russell Investments – Who we are

UK Stewardship Code – Principle 1
Japan Principles for Responsible Institutional Investors – Principle 1
The New Zealand Stewardship Code – Principle 1

1.1 Our purpose
Russell Investments is a global investment firm founded in 1936. Today, it is headquartered in Seattle, USA, with operations in
the EMEA, North America and Asia-Pacific regions. Russell Investments provides investment management, advisory andimplementation (execution) services. As of December 31, 2023, we had over 1,300 associates supporting this delivery and global
assets under management (AUM) of $297.6bn. Our business is built on the partnerships we develop with our clients, helping
them achieve their objectives.
Our organization’s purpose is to improve financial security for people. We seek to bring an unrivalled investment toolkit to bearon our clients’ biggest challenges, always with client interests and preferences at the fore. Russell Investments’ priority foraddressing our clients’ most pressing financial challenges is achieved through open architecture outcome-oriented solutions andembedding efficient risk management techniques. This focus drives our business growth and rapid innovation, and it is built on
our combination of market-leading capabilities:
Manager Research

Portfolio Implementation

Asset Allocation

Total Solutions Management

Portfolio Construction
Since 1980, the primary business has served institutional and retail clients around the world. Russell Investments works withclients of all sizes, from individuals to smaller organizations to large governmental entities, who desire bespoke solutions andbusiness plans that call for continued focus, investment growth, and innovation.

Russell Investments / Investment Stewardship Report/71.2 Culture
At Russell Investments, our culture is built on a commitment to a foundational set of beliefs and practices. These provide a richcombination of real-world guidance and an overarching ethic within which we conduct our business. These are captured in thefollowing four pillars:
1.

Corporate values: Russell Investments' people and values are the foundation of our company and the reason for our longterm success.

2.

Sustainable work practices: Our mission is to identify and reduce our impact on the environment by ensuring that our dayto-day procedures are carried out in the most sustainable manner.

3.

Diversity, equity, and inclusion: We believe that diversity, equity, and inclusion in the workplace drives better performance.
Diversity is integral to our long-term growth.

4.

Community involvement: We are committed to supporting the communities in which we live and work.

1.3 Values
Our core corporate values are summarized below:

We behave with non-negotiable integrity.

We value our people and are dedicated to fostering a meritocracy. Our pillars are inclusivity, humanity,
fairness, hard work, creativity, teamwork, fun and humility.

We play to win by exceeding client expectations and executing with a sense of urgency and purpose.

We are passionate investors who embrace intellectual curiosity and rigor.
These values, which are aligned with our purpose, emphasize putting our clients’ interests first while nurturing a high integrity,
people-oriented culture of innovation, all driving our stewardship practices. Full details of our corporate values can be foundhere.
Sustainable work practices and community involvement have been central to our corporate practices from the company’s
inception. We believe that the effective management of diverse ideas and perspectives brings richness to our culture andincreases our ability to provide innovative solutions to our clients, while adding value for our shareholders and community. Our
efforts to promote diversity, equity and inclusion are detailed in section 7.2 and our corporate social responsibility report, foundhere.
We recognize that staying committed to our purpose requires not only a strong culture but also disciplined and reinforcing
processes focused on oversight and accountability. We provide a detailed description of the governance processes that are
currently in place to deliver on this purpose as part of section 3.

1.4 Investment philosophy
Russell Investments’ open architecture investment approach was developed in the 1960s out of a recognition that the investment
management industry lacked a robust standard of accountability for both institutional and individual investors. As a pioneer ofthe investment consulting industry, we sought to bring objectivity and fiduciary responsibility to every aspect of building andmanaging an investment program. As the architect of the first multi-manager funds, our objective was to bring resources, focus
and a client-centric view to some of the most important questions investors face - the informed selection and oversight of subadvisers, cost-and risk-aware portfolio implementation, and the creation of truly outcome-oriented investment solutions.
Multi-manager investing has risen in popularity over the years but not all follow the same approach. We believe that open
architecture investing is optimally effective when done with appropriate care as it enables independent oversight, drives
innovation in stewardship practices, enforces greater transparency and accountability among investment managers and service
providers, and facilitates the appropriate incorporation of ESG considerations in investment decision making.

Russell Investments / Investment Stewardship Report/8

Russell Investments has established a set of investment beliefs to provide a transparent and objective framework that facilitates
an effective internal decision-making process and guides the delivery of all our investment solutions.
1.

Outcome-orientated investing – Investment decisions are more impactful when they directly serve the achievement of client
objectives, respect for client preferences, and consideration of client circumstances.

2.

Open architecture – Independent consideration, informed diversification and intelligent implementation of the right asset
classes, best investment strategies, and appropriate risk levels give investors the highest chance of success. The ability toidentify skill-based and differentiated processes is a critical edge.

3.

Investment discipline – Investors require rigorous decision-making paradigms, excellent analytical capabilities, and an
ability to think and act independently to deliver superior outcomes.

4.

Effective risk management – Real-time measurement and management of risk must be integrated into the management of
portfolios and solutions to ensure well-informed decision-making.

5.

Dynamic portfolio management – The ability to adapt to changing market conditions is critical to investment success.

6.

Specialization leads to investment decisions at the point of greatest insight – Informed and objective assessment ofinvestment excellence is foundational to the success of open architecture, both in selecting sub-advisers and in evaluatingand enhancing internal capabilities.

7.

Independent review and control support a strong investment process – The best investment processes incorporate objective
analysis and feedback to identify opportunities to improve.

8.

Responsible investment – Russell Investments believes ESG factors can have a material impact on investment outcomes.

1.5 Our responsible investing framework
Responsible investing is at the heart of our investment beliefs. As a global investment solutions provider, we believe thatinvesting responsibly can help to deliver attractive investment returns and meet client objectives in the long term. To this end,
we execute an integrated responsible investing practice across the firm. This practice is founded on the following set of four
core beliefs, codified in 2015:

Exhibit 1: Responsible investing beliefs

Source: Russell Investments, for illustrative purposes only.

Russell Investments / Investment Stewardship Report/9Drawing on the core responsible investing beliefs outlined above, Russell Investments has developed formal policies on
responsible investing, climate change risk and sustainability risks, which are regularly reviewed to ensure they develop in
accordance with market best practice, as described in the “Reviewing Policies and Processes” section of this report. These
policies are the foundation of our efforts to efficiently integrate ESG considerations into our investment manager evaluation
process, our portfolio management, our advisory services, and when implementing proprietary solutions as desired by clients.
Further information regarding how we integrate stewardship and investments can be found in section 4.

1.6 Our history of innovation
At Russell Investments, our service and product set has evolved over time in response to the most pressing threats to our clients’financial security. We have built our business on the strength of a series of innovative products and services aimed at helping
institutional and individual investors invest intelligently through an open architecture investment approach. These havepromoted better functioning in financial markets by raising standards around the quality and transparency of investment
management, as well as the development of powerful tools for investors everywhere.
This began more than half a century ago, in response to the difficulty pension plan sponsors had in monitoring and evaluating
performance, Russell Investments promoted the ‘Deitz’ method for calculating time-weighted returns, invented by Peter Deitz,
the company’s first Director of Research. Following on from that success, we pioneered the practice of vetting and evaluating
active asset managers on behalf of our clients - the manager research practice that has been our most well-known capability for
decades. As we introduced manager research to various markets in Europe and Asia, we were able to establish and spread a defacto global standard of investment excellence by evaluating their investment product according to common criteria andanalytical tools. As major clients around the world used our recommendations to determine allocations, this contributed tosignificant improvements in quality standards and in investment practices across the industry.
When evaluating active asset managers, we detected gaps in the available benchmarks in the marketplace. This led to industryleading efforts to develop styles, style indexing, smart beta and, ultimately, factors. Our innovations in style indexing haveestablished practices, such as transparent selection, float-adjusted capitalization weighting and comprehensive market coverage,
which have been subsequently adopted across index providers. This work was foundational to establishing factors and styles asfundamental to understanding market-wide risk and return.
In addition to these contributions, we were early adopters of global investing and multi-asset portfolios as methods to balancerisks and capture market opportunities. Our experience of managing multi-manager portfolios led to new approaches to tacklingtrading inefficiencies associated with the use of multiple sub-advisers. These innovations retained the benefit of using multiple
best-in-class managers while lowering risk and cost and enabling substantial customization. Our solutions have given Russell
Investments a birds-eye view into the needs of our clients and consistently reinforced our commitment to improving financial
outcomes on their behalf.
We have found many opportunities to protect investors against avoidable cost and implementation slippage. We introduced
commission recapture in the early 1990s, followed by transition management and the development of the T-standard - a
proprietary measure to transparently show the success of a manager transition and its costs. As we continue to innovate our
trading practices, we have been asked by our clients and industry partners to engage with regulatory bodies to ensure that thebusiness of investing can carry on with fewer roadblocks and detours, while also assuring appropriate incentive structures andgood outcomes for asset owners.
Our innovation in the space of responsible investing has been no less impactful to supporting our clients’ outcomes. Our
manager research analysts began evaluating active money managers on ESG integration in 2014, followed by researching
decarbonization data and quantitative methods in 2015, enabling the launch of our first low carbon funds in 2017. We continue
to evolve our understanding of climate risk, most notably through the use of climate models and scenario analysis, now
facilitated by our partnership with the climate model provider Planetrics.
These examples, which are core to our investment approach and services to clients, address clear and present financial risks andhave driven improvements in the function of the financial system overall. We hope that our culture, responsible investing beliefs,
policies, and practices enable effective processes which serve the best interests of our valued clients, who are described in thesection below.

Russell Investments / Investment Stewardship Report/ 10

2. Russell Investments – Who we are

UK Stewardship Code - Principles 4, 5, 6
Japan Principles for Responsible Institutional Investors - Principle 6
The New Zealand Stewardship Code - Principle 8, 9

2.1 Our clients and assets under management
Russell Investments’ focus is on solving our clients’ problems, and in doing so we proactively seek their views on stewardshipand responsible investing. We take account of our clients’ needs through formal surveys as well as more informal feedback at
client meetings.
The investment time horizon is a crucial consideration that plays into both the optimal investment solution and the approach tostewardship. The majority of our clients’ assets are invested to meet long-term objectives. These clients include defined benefit
pension schemes, individual retirement savings plans, and insurance company assets, but even within broad groups of clients,
the time horizon may vary. For example, for defined benefit clients, the investment time horizon can range from around 10 years
for more mature schemes to 30 years or more for younger schemes open to future accrual.
Our stewardship efforts cover both our retail and institutional client base, as well as all asset classes. For each client, we seek tounderstand their overarching objectives, attitude to risk, limitations (i.e., liquidity requirements) and time horizon. Ourinvestment process is designed to tailor our products, solutions, and stewardship activities accordingly. This point is addressed
further in section 2.4 below.
Details of our global client base are provided in the charts below.

Exhibit 2: Assets under management split by retail vs institutional

28%
Global (in $bn) Institutional $138.5

72%

Global (in $bn) Retail $54.1

Source: Russell Investments, data as of December 31, 2023.

Russell Investments / Investment Stewardship Report/ 11

Exhibit 3: Institutional assets breakdown by client type and asset class
Global: Institutional breakdown by asset class4%

Alternative Investments

1%

Cash

20%

Equity52%
Fixed Income

12%
11%

Multi-Asset
CPS

Global: Institutional breakdown by client type
Balance Sheet Assets (in $bn) $6.19
BD/Pension Public or Government (in $bn) $29.36

5%4%
17%

DB Other (in $bn) $1.01

21%

DB Pension Corporate (in $bn) $48.94

1%
2%

DC Corporate (in $bn) $9.23
1%

7%

DC Other (in $bn) $9.94
Distributor (in $bn) $3.27

7%Insurance (in $bn) $0.99

35%

Other (in $bn) $23.34
Tax Exempt/Charity/Endowment/Foundation (in $bn) $6.31

Source: Russell Investments, data as of December 31, 2023.

Exhibit 4: Assets under management split by internally and externally managed1

43%Externally Managed AUM ($128.6bn)

57%
Internally Managed AUM ($169.0bn)

Source: Russell Investments, data as of December 31, 2023

1

Externally manage assets relate to assets managed by third party investment managers. Internally managed assets related to assets managed in house includingthat of overlay services mandates.

Russell Investments / Investment Stewardship Report/ 12

Exhibit 5: Retail assets broken down by asset class ($bn)

14%

9%

Alts ($4.9bn)
Cash ($0bn)
Equity ($27.3bn)

27%

Fixed Income ($14.4bn)

50%

Multi-Asset ($7.4bn)

Source: Russell Investments, data as of December 31, 2023

Exhibit 6: Assets under management split by geographies ($bn)

9%

5%

2%
USA ($156.9bn)
Canada ($8.2bn)
53%

29%

EMEA ($85.8bn)
Australia & New Zealand ($25.7bn)
Japan ($14.5bn)

3%

Asia ex Japan ($6.4bn)

Source: Russell Investments, data as of December 31, 2023.

2.2 Client communications
Once a client is onboarded, we ensure their assets are managed in line with their goals and expectations through ongoing due
diligence updates and regular update meetings. In our experience, interest in stewardship and active ownership matters is
growing, and we have made various training sessions available to our client base. Our process for client reporting combines
information and knowledge from three separate groups.


Our globally integrated Investment Division (ID), which has a vast array of core data and analytics used for investment
decision making, process monitoring, and regulatory body reporting.

Business groups servicing our clients in each region who understand specific client reporting needs.



Our localized compliance and legal teams review client specific reporting before it is released to ensure each report is fair,accurate and in line with local regulatory disclosure requirements.

In practice, applicable data and analytics used by the investment division in its day-to-day decision making is made available toour business teams servicing clients. Depending on the area of reporting, senior members of our ID work closely with our client
service teams and clients directly, to help determine the scope, frequency, detail, and format of reporting for each client andhow to efficiently pull that together from our core data set. Information is scrutinized at multiple levels by senior members of theID, including the Investment Practice Team, client service teams and by local compliance teams, before reports go to clients inspecific regions.

Russell Investments / Investment Stewardship Report/ 13Institutional client communication
We want our clients, at all times, to be well informed about the assets under our stewardship. We meet with our institutional
client base on a regular basis (quarterly in most cases) and where appropriate seek to incorporate their views into ourinvestment and stewardship policy. In addition, we provide our institutional client base with the following sets ofreports/statements:

Training
We provide our client base with both ad hoc and scheduled training. Ad hoc training typically takes placeat trustee meetings, whereas scheduled training takes place in the form of in-person seminars or webinar
sessions. Further details are provided below.

Quarterly performance reports
Bespoke client reports are produced on a quarterly basis and report on the performance of the assets,
liabilities and funding level. They also provide details of asset class allocation and performance attribution.
In addition, these reports provide details of portfolio positioning and the rationale for any changes thathave been made or are planned. Our reports include key ESG metrics (where relevant) – including ESG risk
scores and carbon footprint – and we have recently enhanced these to provide clients with a breakdown
over time, showing how their portfolios are evolving moving forward.

Equity level ESG report
We offer a detailed ESG report for all equity allocations which sets out the ESG risk score and carbon
footprint metrics. Additionally, it provides a distribution of ESG risk scores and details of the highest andlowest ESG scores. Fixed income metrics are also available, and we are developing systems to make thesemore readily accessible.

Active ownership disclosures
This annual Investment Stewardship Report provides an opportunity to showcase in detail our commitment
to active ownership, our approach, annual proxy voting statistics and observed trends. This detail includes
engagement statistics and case studies as well as details of our industry collaborations.

Stewardship policies and procedures
All policies and procedures with regard to stewardship are available to our clients on our webpage. These
are updated on an annual basis as further detailed in section 7.4.

Annual implementation statement
We have worked with our UK institutional client base to produce an implementation statement. This is
produced on an annual basis and coincides with the scheme’s reporting year-end. This statement reports
on how the scheme has complied with the policies and objectives set out in the Statement of Investment
Principles.

Russell Investments / Investment Stewardship Report/ 14

Retail end-consumer communication
Communication with end-retail consumers of our products differs from the above. Information about our stewardship practices,such as manager and investment research processes and ESG integration and operational proficiency, is made available during
the institutional clients and professional intermediaries RFP and due diligence reviews. Once onboarded, the following pieces of
information are also available to our professional clients and (where relevant) their retail customers:

Training
We provide informative literature on our website and at periodic events we host to ensure our clients arewell informed about our investment products, their performance and how they have been affected, or may
be affected, by market influences. We also provide training and literature in relation to broader investment
outcomes associated with our products; this includes the impact of ESG issues.

Fund factsheets
Fund factsheets containing key information about the fund, including performance objective,
benchmark, portfolio statistics breakdown (country weighting, volatility, etc.), are made publicly
available on our website and via third-party data warehouses (e.g., Financial Express and Morningstar).

Key Investor Information Document (KIID)
In Europe, KIID documents are made available for all funds on our website and via third-party data
warehouses and all appointed sub-distributors. The KIID details the fund’s objective and investment
policy, risk-reward profile, applicable charges and past performance data.

Prospectus
The fund prospectus which contains all fundamental information about the fund, its structure, any
management restrictions and a list of available share classes, is made available to all investors andpotential investors on our website, third-party data providers and all appointed sub-distributors.

Active ownership disclosures
We showcase our commitment to active ownership, our approach, annual proxy voting statistics andobserved trends this annual report. Readers will also find engagement statistics, case studies and detailsof our industry collaborations.

Monthly and quarterly performance reports
In addition to the fund documentation mentioned above, live performance data is also made available by anumber of third parties, including Morningstar and Financial Express. We provide further information
around fund management and current holdings to supplement this publicly available data. Clients withsignificant assets under management may also request bespoke reporting, which we would provide on amonthly or quarterly basis.

Russell Investments / Investment Stewardship Report/ 15

2.3 Client training and development
As outlined above, we provide a range of training and development opportunities to our client base to ensure that our clients are
kept abreast of key industry developments. Our annual training schedule is informed through feedback received through client
surveys, as well as topics chosen by our in-house experts. We also provide timely insights and thought leadership content
through our blog and regular LinkedIn updates.
In 2023, we hosted a range of webinars, some of which are highlighted below:

Summer Forum (EMEA)At this half-day event, Russell
Investments experts presented on thefollowing topics: private markets,
macro Environmental, Social andGovernance (ESG) themes andsustainable equity.

Global Market Outlook
Quarterly updates sharing ourstrategists’ market expectations
throughout 2023.

PMI Roundtable on ESG(EMEA)
After the turmoil of 2022, has yourScheme’s focus on ESG changed? Do
you expect to alter your investment
approach over the next 1-2 years?
 How much emphasis are you
putting on;
 Endgame planning and de-risking
 Incorporating ESG into Fixed
Income Private markets and impact
investing Investments aligned to what is‘morally good’ i.e. biodiversity
 Improving your scheme’s
governance

ENGAGE 2023 (Canada)
At these 2-day events hosted in
Toronto and Seattle, discussions
focused on the markets, productinnovations and business solutions.
Looking at how our institutional
heritage, proven investment process
and manager research work together
to help achieve client goals.

ESG Survey webinar(North America)

Energy Transition webinar(North America)

In this panel session hosted byRussell Investments, invitedmanagers examined: How are ESG trends reshaping
Japanese investor preferences
and affecting their dialogue withfund managers and internal
decision making?
 Major priorities andconsiderations when integrating
ESG into investments, from asset
allocation to portfolio monitoring.
 How do institutional investors
think the priorities will change in
the next five years?

In this webinar, our experts
discussed a systematic approach torepositioning concentrated stock
positions in a custom, tax-efficientmanner by using separately managed
accounts, covering:The risks and challenges ofconcentrated stock positions.

A detailed case study of a taxefficient personalized portfoliotransition to direct indexed
strategies.
How we work with advisers todevelop a custom transition
plan and implement ongoingtax- management.

Russell Investments / Investment Stewardship Report/ 16

2.4 Taking account of client preferences

UK Stewardship Code – Principle 6, 7
Japan Principles for Responsible Institutional Investors – Principle 6
The New Zealand Stewardship Code – Principle 3

We pursue integration of stewardship and investment through a process that ensures all key allocation decisions aim to supportclient objectives, while incorporating an understanding of material ESG risks and other financial factors over relevant time
horizons. Every solution starts with an understanding and incorporation of client preferences, and our approach to stewardshipand responsible investing is globally consistent, integrated and applied across funds and asset classes. All else equal, clientswith the same objectives will be provided with the same investment solution based on our best global investment ideas andinsights. However, in creating solutions for a diverse client base, all else is often not equal.
To ensure solutions are optimally engineered to meet clients’ objectives, we apply a three-step investment approach referred toas Design, Construct, Manage (DCM). Our responsible investing beliefs and practices infuse and inform each of these three steps
through the building blocks of our strategic asset allocation, market and manager research, portfolio management and active
ownership capabilities.

DesignCentral to the “Design” step of our investment process is taking client preferences into consideration. We work with investors toestablish clear objectives and to fully understand their preferences, constraints, and circumstances. We use this sharedknowledge to develop an investment roadmap, or strategic asset allocation (SAA). This SAA is built around not only required
investment returns, but also time horizons, risk appetite, fee sensitivity, liquidity requirements and other critical conditioning
factors that determine the most appropriate mix of asset classes and return drivers.
Time horizon, for example, may have a substantial impact on the mix of assets selected and their allocations, particularly
allocations to illiquid assets or return sources whose payoff may be seen as most reliable over a longer time-period (but less soover shorter horizons). Our forecasting engine supports this by providing a framework to create an array of scenarios which
extend decades into the future and help model asset combinations and the liabilities they seek to meet.
A standard approach in the production of capital market assumptions (CMAs) is to assume key economic and financial variables
will revert over time to their long-run trend or reach some sort of "equilibrium" level. However, incorporating climate change
risk into these long-run assumptions is a more complex task requiring probabilities around a range of future climate scenarios.
To enhance our climate modelling toolkit, Russell Investments partners with an external specialist climate risk provider. We
produce baseline CMAs that use historical long-run economic and financial data (referred to as "climate-agnostic CMAs"), andthen "shock" the CMAs based on different climate scenarios and their potential economic and financial impact to produce"climate-adjusted CMAs". This enables us to compare the potential portfolio impact of different climate scenarios across asset
classes and exposures.
We use our climate-adjusted CMAs to support clients who want to further understand the impact of various climate scenarios on
their asset allocation decision. This enhancement also supports clients’ climate related disclosure requirements including theTask Force on Climate-Related Financial Disclosures (TCFD).
We continue to evolve our modelling and reporting capabilities and expect to re-evaluate climate vendors in 2024.

Construct
In the “Construct” step of our process, we seek to find and utilize investible strategies that capture the desired SAA exposures,
while adding excess return through superior active management. We believe that best-in-class investment managers can identify
idiosyncratic mispricing of individual securities and possess the ability to outperform the market through their selection skill anddynamism. We maintain world-class teams of manager due diligence analysts dedicated to identifying and recommending
investment managers with an established edge in their area of focus.
In our open architecture approach, our manager research due diligence teams rigorously pit the best strategies against eachother in our efforts to find the very best. An evaluation of ESG considerations is an integrated component of that process acrossasset classes and geographies. Russell Investments’ portfolio managers select their active managers from among those ranked
highly by our manager research teams, using the ESG assessment in balance with other key criteria, while staying mindful of
return targets and profile and exposure data. When constructing multi-manager portfolios with sustainable objectives from a
combination of sustainable or thematic sub-adviser strategies, portfolio managers use an additional framework to validate thesustainable credentials of those products. This framework is referred to as I-P-O, for Intent, Process, and Outcome. Additional
details can be found in section 4.1.

Russell Investments / Investment Stewardship Report/ 17

Manage
The objective of the “Manage” step of the process is to keep the solution on track for success by adapting to changing market
environments, effective risk management and attention to efficient implementation. We believe that the fear and greed cycle
allows for a robust, process-driven, dynamic management approach, to both add incremental return and to manage risk more
effectively over the course of a market cycle. We dynamically manage portfolios with this process by including both quantitativeand qualitative analysis of material risks. When this analysis creates a high conviction short term view, we are able to taketactical positions. This is most common when markets have moved to extremes of fear or greed.
Like market, credit, and other risks, portfolio managers seek to identify, assess, and manage financially-material sustainability
risks on an ongoing basis within portfolios. Potential risks are identified using available metrics, proprietary scoring, manager
reporting, and through communication with sub-advisers. As one means of addressing these risks, our portfolio managers work
hand-in-hand with our active ownership team to ensure alignment with our proxy voting and engagement activity. We share
more details on these practices in the section on “ESG Integration”.

2.5 Climate aware solutions
As responsible investing has become more complex, Russell Investments’ approach has evolved to address those complications
for institutional investors. While a decade ago a climate-aware portfolio may have revolved around divesting from fossil fuels,
our approach today is much more nuanced. Now, we take a total-portfolio view within our multi-manager framework.
The question, “What is my exposure to fossil fuels?” is comparatively straightforward to measure and deliver. In contrast,
today’s solutions deliver more refined exposures, leveraging manager strategies and proprietary techniques to enable outcomessuch as:

Reduced carbon intensity of the portfolio (emissions per unit of revenue)High carbon intensity but with increased investments in green technology or better alignment to the EU taxonomy

High exposure to energy companies but with company engagement to encourage the adoption of science-based targets, anapproach that has the advantage of promoting adaptability and supporting the energy transition

Each of these strategies are “climate-aware” but expressing or capturing a different opportunity set. Through Russell
Investments’ unique multi-manager, open architecture platform, we can provide transparency across the total portfolio, as wellas the capability to manage exposures. Our portfolio managers assist clients to take advantage of this evolution in approaches,
while still maintaining a focus on outcomes at the total portfolio level.

Carbon managed portfolios
While our process is cognizant of material climate-related risks and opportunities across all our funds, Russell Investments has ahistory of collaborating with clients to build mandates that explicitly target climate-related outcomes such as carbon emissions,fossil fuel reserves, and renewable energy exposure.
As of December 31, 2023, we had approximately $14.4bn in carbon-managed strategies. Our products are built with proprietarycarbon metrics and other relevant data, and currently we measure carbon footprint using Scope 1 and 2 emissions and data from
MSCI. These strategies are often built with a specific carbon reduction target such as a 25% or 50% reduction in weighted
average carbon intensity (WACI) or exposure to fossil fuel reserves.
In 2023, we saw the launch of three new sustainable funds across global markets and asset classes.

Russell Investments / Investment Stewardship Report/ 18

Case study – Sustainable fund launches in 2023

Sustainable Global
Equity FundThe Global Unlisted
Infrastructure Fund

Buy and Maintain Fixed
Income FundThis multi-manager fund benefits
from diversified exposure to fivehighly-rated specialist sustainable
equity managers. Thoughtful
portfolio implementation targets
sustainable and net zero objectives
and reduced risk without lowering
expected return. The fund waslaunched in separate account andcommingled structures in EMEA
and in Australia.

The Global Unlisted Infrastructure
Fund (GUI) is designed to be a
global and sector- diversified openend, core-plus fund, investingexclusively in the infrastructure
asset class. The Global Unlisted
Infrastructure Fund invests inassets that provide essential
services to enable, sustain orenhance economic activity andstandards of living, producing
quantifiable ESG outcomes.

The Russell Investments Buy and
Maintain strategy uses a highly
customizable approach to build
investment-grade credit portfoliosthat aim to deliver smooth andpredictable cash flows to investors.
The flexibility of the strategy
enables investors to set andachieve sustainability objectives,
without compromising desired
cash flows.

Target setting
Russell Investments recognizes climate change as a challenge to the global economy and the financial well-being of our clients.
We collaborate with investors to address this challenge and achieve positive financial outcomes. In 2021, we joined the Net Zero
Asset Manager initiative (NZAMi) to support the global goal of net zero GHG emissions by 2050. As part of this commitment, wework in partnership with interested clients to develop a roadmap for portfolio alignment. So far, our activity has focused on:performing due diligence on target setting methodologies,

continuously raising knowledge across teams through regular climate training,building new capabilities for tracking progress against climate targets, and critically,

defining our approach for determining whether portfolios are aligned to a net zero by 2050 objective.

Our initial targets were established in 2022, and we expect to provide an update on these in 2027. Below we provide an outlineof the learnings so far.

Update on our approach to net zero target setting
While the concept of net zero by 2050 is relatively clear (i.e., global greenhouse gases emitted should be less than greenhouses
gases captured or removed from the atmosphere by the year 2050), it is less clear what this means for investment portfolios.
Useful frameworks from industry bodies can be leveraged for aligning a portfolio with net zero ambition, but approaches varyconsiderably. As a starting point, we researched several methodologies, with a focus on the NZAMi “approved” target setting
methodologies: SBTi for Financial Institutions, the Net Zero Asset Owner Target Setting Protocol, and the Paris Aligned Investor
Initiative’s Net Zero Investment Framework (NZIF).
A consistent theme across alignment frameworks is the need for multiple levels of targets. In particular, there is growing
recognition that achieving an overall portfolio carbon reduction or temperature score alone is not sufficient. Instead, mostframeworks propose a combination of an overall portfolio target, for example a carbon reduction or temperature alignment, in
addition to increasing the percent of the portfolio’s assets that can be considered aligned. Engagement also has an importantrole, as a mechanism to encourage decarbonization of the largest emitters in the portfolio rather than simply divesting fromthem. This is because decarbonization of the largest emitters will be critical to achieving the global goal of net zero. Finally,
increasing investments in climate solutions is also consistently noted as an important consideration, and potentially anotherexplicit target to be set.
For our own targets, we primarily leverage the PAII Net Zero Investment Framework (NZIF), supplemented with our own
insights. After reviewing a range of approaches, we found the NZIF to be reasonably constructed and sufficiently adaptable toour use case which covers many investment styles, geographies, and asset classes. As noted above, this framework will include
multiple levels of targets. The bottom-up asset alignment measures what percent of securities in the portfolio are aligned,aligning, committed to aligning, or not aligned. To date, we have completed a mapping of open data sources such as Climate

Russell Investments / Investment Stewardship Report/ 19

Action 100+ Benchmark, Transition Pathway Initiative, and the Science Based Target Initiative, as well as our proprietary data
providers.
Over time, portfolios on a net zero trajectory need to increase the percentage of the portfolio in the higher ambition buckets(aligned, aligning). We will also set targets to engage with companies in material sectors who represent significant sources of
GHGs and are lagging on these assessments.
The next type of target, the top-down portfolio level reference, acts as an accountability mechanism for ensuring that the
decarbonization of the portfolio is consistent with a science-based net zero pathway. Portfolio-level carbon emissions must
decrease over time relative to a base year. For example, global absolute GHG emissions need to decrease by approximately
6.7% per year between now and 2030 to be on one of the commonly cited net zero pathways, and this is a common starting
reference for a portfolio decarbonization objective over time. Global emissions need to decrease by approximately 50% by 2030
relative to a 2019 baseline to be aligned to a limited or no overshoot pathway in the IPCC Special Report on 1.5 degrees, and thisserves as another common reference point.
While these reference points serve as our guides, there is nuance around the selection of carbon metrics and accounting for
sector and regional exposures of a portfolio, given the economy will decarbonize at different rates. In a diversified global
portfolio, this may not be critical since the portfolio exposures largely align with the global market on average. However, in an
emerging markets fund, or a concentrated infrastructure fund, sectoral or regional decarbonization considerations can be moremeaningful.
Finally, the Net Zero Investment Framework highlights the critical need for increasing investment in climate solutions. These
investment opportunities can be identified and targeted via the EU taxonomy criteria, although there may be a rationale forusing less stringent definitions of climate solutions as well. We have already acquired EU taxonomy data and have started tointegrate it within our sustainable transition universe development. However, this is still a relatively new area and one that will
require more investigation before robust target setting is possible.

Case study – Net Zero Dashboard
While acknowledging that the complexity of transition cannot be reduced to a single metric, we believe it is important toprovide clear and transparent data points to measure progress. To this end, we invested in building an internal dashboardthat monitors our progress across the three primary net zero sub-targets identified above.

Exhibit 7: Snapshot of sample net zero dashboard

Source: Russell Investments, for illustrative purposes.

OutcomeThe dashboard tracks progress for each underlying fund or account in scope for net zero alignment, as well as an aggregatedRussell Investments portfolio. This aggregated portfolio only represents the 25% of Russell Investments AUM currently inscope for net zero alignment. Above, we report progress for 2023 against the interim targets for the aggregated portfolio.

Russell Investments / Investment Stewardship Report/ 20

2.6 Addressing client needs in practice
We recognize the importance of regular communication and engagement with clients to understand their goals, objectives,preferences, and any constraints they may have expressed in their portfolios. We also understand that our clients’ needs couldchange over time. As a result, we use various methods to gather feedback from clients, such as client satisfaction surveys,
periodic reviews, and ongoing discussions. Whilst our approach does vary slightly from region to region, our methods are
summarized below.

Ongoing dialogue
We believe that the best way to understand our clients' needs is through clear and constant dialogue. This stems from anunderstanding that each of our clients are different and have unique needs. Therefore, having an open dialogue with each ofthem ensures that we are aligned on what they are trying to achieve. This form of engagement typically takes place at quarterly
meetings and intra-quarterly as needed. This allows us to have detailed discussions of their goals, objectives, preferences andany constraints they may wish to have expressed in their portfolios. In certain jurisdictions, we measure the effectiveness of therelationship through the use of key performance indicators (KPIs), such as:Client satisfaction: We ask for performance review feedback from our clients throughout our relationships.

Client retention: We place a strong focus on the tenure of our clients.



Investment performance: Clear articulation and setting of investment objectives based on both our understanding of, andour discussions with, clients.



Bespoke KPIs: We often work with our clients to agree bespoke KPIs around other value-adding services that are ofimportance (e.g., number of face-to-face meetings).

Client satisfaction survey
We also conduct annual client satisfaction surveys where we engage our clients to provide feedback against the objectives they
have set for us. This serves as a useful formal summary of quarterly discussions, and allows for additional comments to be
added, which have fed into both our recent product and reporting enhancements.

Third party survey
We conduct periodic third-party client satisfaction surveys to ensure that we are exceeding our clients’ expectations and provide
an option for clients to submit anonymous feedback and input on how they would like us to evolve our solutions to meet theirchanging needs. The latest in-depth client survey was carried out over the course of 2023. For illustrative purposes, an example
graphic of client survey result received in EMEA has been included in Exhibit 8 below.

Exhibit 8: Example client feedback results

Russell Investments / Investment Stewardship Report/ 21

Case studies
Through the feedback mentioned above, as well as the ongoing internal review of our practices, we have identified the following
requirements/areas of improvement. We provide details of the actions we have taken in the case studies below.

Case study: market insights

Case study – Bi-annual UK defined benefits market insights study
In 2023, we conducted a bi-annual UK Defined Benefits Market Insights Study. This was based on responses of 107 UK
defined benefit schemes, representing a total of over $318bnof assets under management. Around half of respondents were
responsible for more than $1 billion of assets. Russell Investments also conducted interviews with 12 leading independent
trustees to provide additional context to the survey findings.
The intention of this Study was to understand the key priorities and concerns facing stakeholders, including stewardship. As
part of this, the majority of respondents (58%) indicated they were either ‘likely’ or ‘very likely’ to increase their focus on
climate change related issues in the next twelve months, and as shown in Exhibit 9 below, over half of respondents havealready set a net zero target by 2050 or earlier, an increase from 36% in our 2022 Study.

Exhibit 9: Respondents’ targets to reach net zero

15%

10%

2030
13%

2040
2050

32%

Still to be decided30%
We are not setting a net zero emissions target

Source: Russell Investments, December 2023.

OutcomeThe UK Defined Benefits Market Insights Study is conducted on a bi-annual basis, designed to allow us to gather feedback andtrends from both our client base and wider market. This includes, how our focus on Stewardship can help them to reach theirgoals. Based on the results received, climate change and net zero in particular will continue to be a key feature of our
responsible investing agenda for 2024.

Russell Investments / Investment Stewardship Report/ 22

Case studies: Solution development

Case study – Development of Sustainable Global Equity Solution
In 2023, we partnered with a UK client to develop and launch a bespoke Sustainable Global Active Equity Solution. Thispartnership involved understanding, guiding, and developing a set of sustainability criteria which met the objectives of theclient. Following multiple discussions with the client we agreed on various sustainability parameters including a level ofrequired ESG objectives, climate related elements, risk and return tolerances, non-climate sustainability considerations,exclusion requirements and reporting considerations.

Outcome
We were able to draw from our manager research capabilities to identify and access five world-class, global equity specialist
managers, which in combination met the various sustainability objectives that had been identified.
The solution designed also offers the flexibility to evolve as our client’s requirements change, utilizing our Enhanced
Portfolio Implementation capabilities. This infrastructure enables customized changes to the sub-fund under a centralized
portfolio management process.

Note: Diagram for illustrative purposes.

Russell Investments / Investment Stewardship Report/ 23

Case study – Focused ESG strategy for an APAC OCIO client
Through ongoing discussion culminating in an annual investment strategy review with a non-profit OCIO client, we helped
define both new investment objectives and a more ESG-focused investment strategy across the client’s entire portfolio.
We recommended a move to a higher growth allocation to better meet the client's long-term horizon and enhance return
potential, as well as the incorporation of passive oriented ESG solutions. To incorporate higher levels of ESG considerations
into the portfolio, three portfolio options were presented, each showcasing different levels of active and passive
management and varying degrees of ESG objectives. This allowed the client to tailor their responsible investing approach
while considering associated returns and risks. An iterative and phased approach was utilized to pinpoint the optimal mix ofactive and passive exposures, aligning with the client's desired ESG exposures.

OutcomeTwo active ESG options were launched as a result. In the Australian shares, an active ESG option called the Custom Active
Australian Shares SMA was introduced. This enabled the client to exclude stocks that go against their ESG policy without
adopting other investors' socially responsible views in a pooled investment trust, as well as positively tilting to stocks which
offered renewable energy generation and improved ESG risk scores.
In global shares, an active Global Equity Fund was launched, constructed with best of breed sustainable managers identified
through Russell Investment’s manager research and our Intent-Process-Outcome approach. The Fund utilized an approachpreviously designed for a UK client with similar objectives.

Case study – Development of internal dashboard to meet US client requests
Clients are increasingly focused on understanding the diversity characteristics, policies, and practices of their underlying
investment managers, and we are well-positioned to support their needs. We continue to enhance our ability to recommend
asset managers that have favorable DEI characteristics and to report on diversity among hired managers.
Consistent DEI data can be hard to come by, so we leverage multiple data sources., In 2023, we developed an internal
dashboard to assist in monitoring and reporting fund-level sub-adviser DEI data. For Russell Investments in aggregate, wemeasure diversity among managers in our research pipeline, on our recommended lists, and hired in funds on an annual
basis. Furthermore, we provide custom reporting to clients on diversity among hired/funded managers upon request.

Outcome
Our annual Manager ESG Survey suggests that diversity remains an area of high concern for asset owners. The new strategy
allows us to meet the needs of clients looking for greater visibility into the DEI practices and characteristics of ourunderlying managers.

Russell Investments / Investment Stewardship Report/ 24

Case study – Private market development
Over the course of 2023, we discussed the development of private market solutions with one of our UK clients, with a focus
on providing solutions within private markets which can generate meaningful impact while managing and mitigatingclimate-related risks. For this new solution, we worked closely with the client to support them in their long-term ambition todemonstrate leadership on responsible investing practices.
Together with the client, we developed a credit solution, which tracks sustainability and ESG metrics in accordance with theclient’s long-term climate goals. The solution has a focus on opportunities where private, long-term capital can provide
distinct advantages over other capital sources to mitigate climate-related risks.

OutcomeRussell Investments is working alongside the client to identify opportunities that meet the investment parameters outlined
for the mandate while simultaneously helping the client deliver their own responsible investing and social impact policies.
The solution also allows for the client to set specific ESG-related criteria, such as an exclusion of fund investments and coinvestments into strategies that are directly related to companies they wish to exclude.

Case studies: Solution development

Case study – Granular ESG reporting
As clients are facing increasing regulatory requirements regarding their ESG reporting, Russell Investments has been
actively supporting clients in meeting these requirements by enhancing our ESG reporting and providing more granular
data and climate metrics. One such client was required to undertake their first TCFD report in 2023. As part of this process,the trustees identified four climate change metrics against which to measure their asset portfolio and, as required, formally
identified a target against which to measure progress for one of those metrics.
To enable the monitoring of the identified climate change metrics by the client, Russell Investments augmented the ESG
component of the quarterly investment performance report to directly report on these metrics.

Outcome
The enhanced ESG report received positive feedback and covered all the key metrics that had been set out by the trustees,such as Financed Emissions and WACI-scores over time. Furthermore, the inclusion of these metrics in the client’s quarterly
report (as shown below in Exhibit 10) enables the client to easily track the metrics required in their TCFD reporting.

Exhibit 10: Evolution of quarterly client reporting

Russell Investments / Investment Stewardship Report/ 25

3. Governance of stewardship

UK Stewardship Code - Principles 2
Japan Principles for Responsible Institutional Investors - Principle 7
The New Zealand Stewardship Code - Principle 1

Our governance bodies and supporting processes ensure alignment of our activities with our clients’ best interests and effective
stewardship across all our investments, at every level of our organization. Our corporate and investment bodies recognize thatstewardship is central to investment management, and this has been the main organic driver of our evolution as good stewardsof our clients’ investments with us. Below, we provide details of our global and EMEA governance structures and resources, andhow they contribute to a consistent emphasis on high standards of fiduciary duties.

3.1 Global governance structure
At Russell Investments, global governance is headed by our Board of Directors and an Executive Committee (EC). Leadership on
stewardship starts at the top of the organization and is expressed through the empowerment of a number of global committees
to establish practices and oversee their faithful execution. These committees ensure compliance with global investment, risk,
and stewardship standards across all regions, as well as being responsible for introducing continuous enhancements to ourapproach, in line with our best thinking and industry practice.

Exhibit 11: Global governance committees

Source: Russell Investments, for illustrative purposes only.

Russell Investments / Investment Stewardship Report/ 26

The EC is the most senior management group at Russell Investments and is responsible for determining the company’s businessstrategy and overseeing its implementation. Overall direction and emphasis on stewardship is set by the EC as part of investment
strategy and corporate management. In recent years, the EC has strongly supported increased integration and resourcing of
stewardship activities.
The Global Risk Management Committee (GRMC) plays a critical role in our risk management and stewardship practices. It
provides an independent global authority over major areas of risk and control essential for effective management of thecompany.
The GRMC, acting in its oversight capacity, is authorized and directed to review and evaluate investment, credit, and operationalrisks. It provides guidance to the business units for the proper identification, assessment, monitoring, and mitigation of theserisks. It is authorized by the EC, and its responsibilities relate to all legal entities and businesses operated by Russell
Investments, worldwide. Global oversight by the committee for risk management practices is supported by regional risk
management sub-committees in each of Russell Investments’ current business regions. Further information on how Russell
Investments identifies and responds to market-wide and systemic risks is explained under section 2.

Board oversight of climate risk
Russell Investments’ Board of Directors has ultimate responsibility for the strategic priority, corporate governance, and longterm stewardship of the firm. Climate-related risks and opportunities have been identified as a strategic priority for the business.
As a result, significant consideration has been put towards establishing the appropriate governance frameworks to identify,
assess and manage these risks and opportunities.
The firm’s TCFD report is tabled annually at the Audit and Risk Committee meeting. This provides the Board with an opportunity
to further deepen their understanding of the firms’ exposure to climate risk. Russell Investments’ Board, through the Executive
Committee (EC) and Audit and Risk Committee, has delegated oversight of the risks associated with climate change to theInvestment Strategy Committee and the Global Risk Management Committee.

3.2 Investment governance structure
The Investment Division (ID) is responsible for undertaking all investment activities for clients. The ID is governed by theInvestment Strategy Committee (ISC), which is authorized by the EC to oversee investment activities, review investment
performance, and establish investment policy and strategy. The ISC is responsible for processes and standards of stewardshippractice, with a focus on active ownership and creating long-term value through appropriate decision making around allocations
and risk management. As regulatory standards and industry practices evolve, the ISC seeks to continually update investment
processes, including stewardship practices.
The ISC’s members comprise the Global Chief Investment Officer, who serves as the Chairperson, and senior ID and risk
professionals. The ISC delegates to numerous sub-committees to review and recommend proposals to create new investment
products, launch new funds and hire/terminate investment managers.

Russell Investments / Investment Stewardship Report/ 27

Exhibit 12: Investment Strategy Committee

Solutions
Sub-Committee(SSC)
Oversight of design
decisions including
new productlaunches andstrategic asset
allocations.
Evaluates suitability
to end client
requirements.

Proprietary
Strategies
Sub-Committee(PSSC)
Oversight of all
proprietary
strategies andmonitors
performance ofexisting strategies.

Implementation Review
Board (IRB)

Manager &Strategies SubCommittee (MSSC)
Oversight of
construct decisions
for equity fixedincome and mainasset activities.
Approve changes inmodel portfolio
positions. Establish
guardrails.

Investment
Strategy
Committee (ISC)
Responsible for oversight of all
investment activities, including
delegation of key investment
oversight roles and standards.
Creates standards and guidelines
for all investment decision
making, including sources ofreturn, risk budgeting, investor
discretion, andmeasures/monitoring of success.
Final approval of all new
products, processes, andcapabilities.

Alternatives
Sub-Committee(Alts SC)
Oversight of hedge
fund and private
equity fundactivities. Approveschanges in model
portfolio positions.
Establish guardrails.

AffiliatedBusiness
Oversight
Committee(ABOC)

Trade
Management
Oversight
Committee(TMOC)

ActiveOwnership
Committee(AOC)

Investments
Division
Editorial
Board(IDEB)

Reviews and makes
recommendations to the
ISC and appropriate subcommittees on preferred
instruments andpreferred
implementation
techniques.
Recommends andmonitors implementation
guidelines.

Investment Model
Review Board (IMRB)
Reviews and makes
recommendations to the
ISC and PSSC on all new
investment models used
to manage portfolios,
either as separate
strategies or tools.

Investment
Division
Responsible
InvestingCouncil(IDRIC)

Source: Russell Investments, for illustrative purposes only.

The groups reporting to the ISC have written charters outlining their documentation requirements, such as records of approvals,
decisions, and oversight activities. Each of these groups has delegated responsibilities from the ISC, relating to the faithfulexecution of stewardship responsibilities and the continuous development of investment practices for the management of client
assets. Whether those duties relate to ensuring sound investment decisions on behalf of clients, verifying the rigor andappropriateness of investment analysis, or guarding against potential risks or conflicts, they all feed into the broader mission of
improving financial security for people.
Our governance process features performance measurement, with much focus placed on metrics that assign accountability andreflect the outcomes our clients seek. We formally review these metrics and outcomes with the accountable parties on an annual
cycle (and informally more frequently), and we continually revisit mandates, objectives, and performance metrics for theiralignment with the mission of each group.
Every ISC sub-committee is responsible for embedding good stewardship practices into its governance and decision-making
processes. For example, the Manager and Strategies Sub-Committee ensures that proposed portfolio structures are wellconstructed to meet investment targets within risk guidelines. As part of that oversight, the committee must confirm that subadvisers have sufficient ESG capabilities embedded in their overall evaluation and will consider available metrics on ESG factors
when approving portfolio structures.
Within the ID, our Active Ownership Committee (AOC) oversees a globally consistent and rigorous approach to proxy voting andengagement activities. Under this oversight, the Active Ownership Team executes the day-to-day process, maintaining proxyvoting policies, procedures and guidelines, while implementing voting decisions and evolving our processes as needed to meetclient needs and expectations. The AOC is made up of tenured and experienced Russell Investments professionals from a varietyof roles around the world, including portfolio management, manager research and investment strategy. All proxy voting andengagement activities are advised by a member of Russell Investments’ legal team.

Russell Investments / Investment Stewardship Report/ 28

Within the Active Ownership Committee, our Guideline Sub-Committee meets regularly to review and propose adjustments that
ensure our guidelines are aligned with current best practices. Meanwhile, dedicated personnel work alongside our portfolio
managers to direct and coordinate our engagements with public companies, our sub-advisers and other market participants.
This organizational structure, and the diverse set of participating investment professionals, ensures our active ownershipfunction is integrated within our investment process.

Exhibit 13: Active Ownership Committee structure

Source: Russell Investments, for illustrative purposes only.

3.3 Responsible investing governance structure
We favor an integrated approach to responsible investing and have subject matter experts embedded throughout ourorganization. Our responsible investing teams and initiatives are led by an executive sponsor, our Global CIO Kate El-Hillow,
demonstrating Russell Investments’ commitment to these initiatives. Two councils provide governance and coordination for our
responsible investing practices and initiatives, namely the Go-to-Market Responsible Investing Council (GTMRIC) and theInvestment Division Responsible Investing Council (IDRIC).

GTM Responsible Investing Council
Russell Investments’ GTM Responsible Investing Council (GTMRIC) is responsible for guiding our investment deliverables and
Go-To-Market (GTM) activity on responsible investing, as well as charged with ensuring we deliver the best possible responsible
investing solutions and outcomes to our clients globally.
The council consists of representatives from across the business including the investment division as well as product, marketing,legal, compliance, and client-facing teams. Jihan Diolosa, Head of Global ESG Strategy, chairs this council.

Russell Investments / Investment Stewardship Report/ 29

Exhibit 14: GTM Responsible Investing Council structure

GTM Responsible Investing Council (GTM RIC)
Chair: Jihan Diolosa (Head of Global ESG Strategy)

SolutionsSales
strategy

GTMstrategyMarketing

Legal andcompliance

Investment
Division

Investment Division Responsible Investing Council
Russell Investments’ Investment Division Responsible Investing Council (IDRIC) is the principal body of responsible investing
experts at our firm. The council is responsible for devising and leading the Investment Division’s (ID) response to a broad set ofsustainable investing challenges and requirements emanating from our clients, our business strategy, and a changing regulatoryenvironment - typically prioritized and delivered to the ID via the firm-wide GTMRIC. Importantly, the IDRIC, which reports to
the ISC, guides the ID’s responsible investment practice across our investment process.
Specifically, this group ensures that the data, infrastructure, and processes are in place to support effective active ownership andan integrated approach to incorporating financially material ESG factors and risk mitigation into investment decision making.
These responsible investing experts from across our research and portfolio management teams are empowered to propose
improvements in stewardship and investment practice, to be approved by the ISC. The council is chaired by Kris Tomasovic
Nelson, Head of ESG Investment Management.

Exhibit 15: Investment Division Responsible Investing Council structure

ID Responsible Investing Council (IDRIC)
Chair: Kris Tomasovic Nelson (Head of ESG Investment Management)

Activeownership

ESG research

Russell Investments / Investment Stewardship Report

Privatemarkets

Portfolio
management

Manager
research/ 30

3.4 Resourcing stewardship
The ID is organized around three core strengths: research, portfolio management, and implementation services. Some of the key
investment functions most central to stewardship practices include:Manager Research Analysts – Specialists responsible for gaining a thorough understanding of the universe of investable
managers and products and for making recommendations which they believe offer our clients the best opportunities.



Portfolio Managers – Professionals tasked with the strategic asset allocation, manager and strategy selection and daily
portfolio monitoring of Russell Investments’ strategies.



Portfolio Analysts – These professionals work closely with our portfolio managers and provide them with the necessary
analytical tools and research reports to aid their decision making.



Implementation Portfolio Managers – These specialists execute the investment decisions of the portfolio managers, ensuring
the timeliness and efficiency of any changes.



Research and Development – This team is responsible for research of the capital markets and creation of forecasts andinvestment strategies that identify and capture key sources of return. Additionally, the team enables the development of
supporting technologies and tools to effectively deliver our investment insights to clients. Our R&D professionals have thequantitative capabilities to apply the tools of data science and advanced computing to a wide range of investment
challenges.



Asset Allocation & Investment Solutions – Members of this group lead our efforts in asset allocation issues, including all
forecasting and modelling. They also participate in research of institutional matters, such as reviewing and understanding
the implications of pending legislation, or the role of potential new asset classes, such as portable alpha and overlay
strategies and evaluation of less traditional asset classes.



Active Ownership: The dedicated professionals on our Active Ownership Team enable our proxy voting policies, procedures,
guidelines and voting decisions. This team also leads our engagement process with participation from a wider group ofinvestment professionals.

Service Providers: The extent to which service providers are used and the service they provide from a stewardship perspective
is covered in Section 4.4 of this report.

The collective efforts of these functions help to create and maintain solutions that are not only tailored to pursue our clients’return objectives, but also reflect our best thinking in terms of manager research and projected market behavior. This division ofroles and responsibilities is designed to create clear ownership of key decisions matched with appropriate expertise andexperience. We value specialization and clear accountability in these roles, even as we seek to effectively guide all investment
professionals’ activities to collectively contribute to clients’ total portfolios. The table below provides details of our current total
headcount of investment professionals. We believe that this is an effective combination of subject matter experts andqualifications for meeting our stewardship requirements.

Exhibit 16: Total number of investment professionals
TOTAL NUMBER OFINVESTMENT
PROFESSIONALS
Total Investment
Professionals

NUMBER OF INVESTMENT
PROFESSIONALS WITH
CFAS

NUMBER OF INVESTMENT
PROFESSIONALS WITH
PHDS

AVERAGE RUSSELL
INVESTMENTS YEARS’TENUREAVERAGE INDUSTRYYEARS’ EXPERIENCE

320

155

9

11.1

Source: Russell Investments, data as of December 31, 2023.
Associates are encouraged to pursue educational opportunities to develop skills and meet their career goals. Russell
Investments’ associate development program holds managers accountable for working with their direct reports to create adevelopment plan with the goal of growing existing and developing new skill sets. Furthermore, we encourage participation incontinuing education opportunities, such as the Chartered Financial Analyst program, to enhance knowledge through job-relatedareas of study, or pursuing licenses and professional designations applicable to their positions. To further encourage associates,
a generous tuition reimbursement program for qualified programs and areas of study is in place.

Russell Investments / Investment Stewardship Report/ 31

Specific to responsible investing, both broad and role-specific training is required for key investment professionals, ensuring anappropriate understanding of ESG concepts and topics as they seek to deliver strong investment outcomes and stewardship toclients. In addition, client-facing teams have continual access to regular training on capital markets, investment strategy, asset
class behavior, and portfolio management innovations.

Case study – Rotational proxy analyst program

Russell Investments’ proxy voting program leverages an extensive, bespoke set of proxy voting guidelines, but somecategories of proposals require more careful review and assessment. The first step in this process is conducted by aninternal proxy analyst who evaluates the proposal and prepares a recommendation for our Active Ownership Committee on
whether to support or reject it. As the number of shareholder proposals requiring a deeper review has increased, Russell
Investments has in turn expanded our ranks of proxy analysts.
Our internal proxy analysts, who serve on a two-year rotation, are members of the investment division, typically portfolio or
manager research analysts, globally distributed and from different asset classes. The Active Ownership Team provides
training to the analysts on an annual basis and oversees the vote recommendation process.

OutcomeThis program provides training on active ownership to an expanded number of our investment associates, while supporting
the evaluation of a significant number of complex proxy decisions.

3.5 Alignment of incentives to integrate stewardshipAs a global organization, we have made the consideration of ESG and effective stewardship across all investment decisions a key
objective. Senior portfolio managers are compensated based upon a combination of factors which encompass their success indelivering desired investment outcomes to clients, while effectively contributing to investment processes and providing suitablelevels of stewardship of client assets. Within that overarching evaluation framework, portfolio managers are required to consider
ESG factors and stewardship in evaluating and selecting sub-advisers, as well as evaluating ESG risks and exposures at the total
portfolio level and pursuing engagement opportunities. Portfolio managers’ effective incorporation of these factors is explicitly
measured, included in annual assessments, and linked to compensation.
In addition to senior portfolio managers, all associates with specific responsibilities for ESG, stewardship and climate change
have annual performance goals aligned with the success of the integration of these topics. These goals include evolving our
responsible investing and stewardship practices to be in line with global standards; collaborating with leading industry bodies toadvance industry frameworks; driving our engagement practices; and research and development. All these items are aimed atdelivering robust stewardship practices to meet our clients’ objectives. Success in meeting these specific stewardship and ESGrelated performance goals is linked to remuneration.

Russell Investments / Investment Stewardship Report/ 32

4. ESG Integration and Responsible Investing

UK Stewardship Code – Principles 2, 7
Japan Principles for Responsible Institutional Investors - Principle 7
The New Zealand Stewardship Code – Principle 3

4.1 Our integrated approach to stewardship and investment
As a function of our integrated approach, material ESG considerations and stewardship are woven into our standard investment
practice at all stages of our investment process. Subject matter experts are embedded within our research, risk, analytics,
quantitative and portfolio management teams, and work in close coordination with dedicated responsible investing and active
ownership personnel. Our professionals understand the ways in which sustainability issues manifest in the financial performanceof various investments across asset classes, and their aim is to identify and act on material financial risks and opportunities.
Below, we describe how our responsible investing beliefs and policies, detailed in section 1, translate into practice within our
key investment capabilities.

Exhibit 17: Responsible Investing in practice

Source: Russell Investments, for illustrative purposes only.

Russell Investments / Investment Stewardship Report/ 33

Belief 1 – ESG factors can impact security prices
Portfolio Management Process
Responsible investing is integrated throughout our investment process, including our manager research, portfolio management
and portfolio construction activities. We believe that material ESG considerations should sit alongside traditional assessments as
a part of the overall strategy evaluation. Since 2014, our manager research analysts have evaluated how effectively investment
managers assess and manage ESG issues within their investment process as a standard component of our diligence across all
asset classes. Analysts leverage both quantitative and qualitative information in conducting each review, drawing on external
data and research from providers including Sustainalytics and MSCI. Equity research analysts can view Sustainalytics’ and MSCIESG data for each sub-adviser strategy we monitor via proprietary tools and ESG reporting. Our analysts also utilize information
gathered from our Annual ESG Survey, which broadly polls active equity, fixed income, and private markets managers tomeasure the state of ESG integration across the industry investment practice. We are continually evaluating and working toincorporate additional data sets for all asset classes.
Our ESG-related due diligence covers a wide set of sub-advisers’ stewardship activities, as described under the four subcategories in Exhibit 18 below. The ESG sub-rank, which is shared with clients alongside our other sub-ranks, ranges from one
to five, with a ranking of three considered consistent with the peer group average.

Exhibit 18: ESG sub scores

Source: Russell Investments, for illustrative purposes only.
Russell Investments’ research analysts maintain ESG sub-ranks on nearly 1,750 strategies across all asset classes andgeographies. In addition, more than 400 manager strategies researched by analysts have been identified as having a specific
ESG outcome intent as part of their investment process. In 2023, 55 of those products had their assessment ranks updated
following research meetings that included more than 100 of these strategies. Greater visibility into the drivers of the ESG rank
has prompted greater understanding of how ESG factors influence a manager’s potential outcomes and has offered improved
transparency to portfolio managers and clients. While analysts assign an ESG rank to all high interest and recommended
strategies, and it is just one of several areas of due diligence, the drivers behind a manager’s ESG approach are naturally ofparticular importance to those strategies which aim to deliver explicit sustainable objectives.
For mandates with explicit sustainable objectives, we ensure that portfolio managers select strategies with strong ESG
integration through a framework at Russell Investments known as Intent, Process, Outcome (I-P-O). Product intent reflects astrategy’s philosophy or objectives. A manager’s process is evidenced by consistent and effective integration of ESG andresponsible investing practices at the fund level. Finally, a sustainable or ESG outcome is evidenced through productcharacteristics. These will differ by asset class but may include the target investment type, low ESG risk, revenue alignment, or
low carbon emissions. Through close collaboration and clear documentation, research analysts and portfolio managers use I-P-O
to validate the sustainable objectives and capabilities of a strategy prior to inclusion in our multi manager sustainable funds.
Russell Investments / Investment Stewardship Report/ 34

Analysts record their analysis and conclusions, including ranks, in our global proprietary database, RADAR (Russell Investments
Analysis, Data, and Ranks). Further details about RADAR and the way we hold managers accountable through due diligence areprovided under section 4.4.
Russell Investments’ portfolio managers select active managers from among those ranked highly by our manager researchteams. The Investment Strategy Committee and its delegate committees confirm that sub-advisers selected by portfolio
managers for client solutions have sufficient and appropriate ESG capabilities for each fund assignment.

Case study – Manager change to enhance ESG integration in the Global Credit
Fund
ESG integration in the fixed income market is rapidly evolving, and our open architecture platform allows us to partner withleading asset managers who have superior investment frameworks. Among other capabilities, compelling managers are able
to consistently and effectively identify ESG-related risk and return opportunities. In the fixed income space, our manager
research team sought to enhance the manager line-up in the Global Credit Fund where the client was looking to improve theoverall profile of sustainability in the Fund.

OutcomeAfter conducting numerous due diligence meetings, our manager research team identified a sub-adviser who offers acompelling performance expectation with a convincing practice of assessing ESG-related risk and return opportunities intheir investment process. As a result of hiring the newly identified manager, the average ESG assessment rank for the Fund
improved, and there was a material improvement in the carbon footprint intensity measure. Furthermore, engagement
activities in the Fund are expected to improve after this manager change.
Portfolio managers manage sustainability risks in our investment solutions through our quarterly and annual manager review
process and through implementing proprietary solutions. Through a process known at Russell Investments as ‘Enhanced
Oversight’ (EO), portfolio management teams assess sustainability risks in funds and explain how those risks are being
monitored and managed. EO is designed to provide sufficiently granular insights into fund/portfolio exposures - without
adopting a ‘checklist’ approach that would fail to recognize the breadth, complexity, and relevance of sustainability issues. EO
focuses on broad ESG themes as well as specific securities identified from:

Our own quantitative analysis, where we monitor the highest and most material sustainability risks at the total-portfolio levelSub-adviser insights, whom we explicitly direct to highlight financially-material sustainability issues

Other third-party sources including those who provide company and thematic ESG research

Quantitative analysis is used wherever data is available and robust, particularly in equities where our primary data sets include
Sustainalytics’ Risk Rating, Carbon Footprint and Russell Investments’ Material ESG Score. Russell Investments’ proprietary
Material ESG Score is designed to highlight sustainability issues that are relevant and specific to a particular company and its
industry. In calculating this score, we utilize Sustainalytics, SASB’s Materiality Map, corporate governance scores andenvironmental data from multiple providers with an emphasis on forward-looking information where available.

Russell Investments / Investment Stewardship Report/ 35

Case study – ESG module development for portfolio analytics

OutcomeIn 2023, we completed a project which added an “ESG module” to our portfolio attribution and analytics platform. The
project enabled real time calculation of ESG-related exposures at the fund, manager/sleeve, and security level while
incorporating information from the firm’s enterprise data workflow (ERMS). The module delivers data from vendors such as
MSCI, Sustainalytics, and Planetrics to enable portfolio managers to monitor ESG objectives and constraints at a portfolio
level across the suite of funds and client accounts. This includes equity, fixed income, and multi-asset strategies.
To share ESG-related insights across teams, Russell Investments uses an internal platform called ENACT. The name ENACT was
drawn from the combination of two of our critical responsible investing practices: Enhanced Oversight and Active Ownership.
ENACT allows investment team members to record and access the insights that are gathered during sub-adviser oversight(including EO) and from engagement activity.
Critically, ENACT maps an issuer’s securities across funds, enabling coordination between fixed income and equity experts, andit serves as a timeline and progress marker for our engagement objectives. We believe that setting and tracking explicit
engagement objectives is key to an effective program, and we were early in implementing process and tool for this. We continue
to evolve ENACT by adding data and enhancing its functionality. For example, in 2023 we made changes that promoted
complementarity between ENACT and our Net Zero Dashboard with the aim of streamlining our net zero engagement planning.
Russell Investments is pleased to be operating according to best practices in this area.

Case study – Enhanced oversight within an emerging market fundESG-related data is notoriously scarce for emerging market companies as many firms do not disclose the same information
as their developed market counterparts. Enhanced Oversight allows our teams to overcome this hurdle and more accurately
assess holding companies in these regions. Where our portfolio management teams have the opportunity to gather risk andopportunity information from the EO process, it can lead to engagement with the identified company.
An example of this process is shown through our exposure to a Mexican construction materials company. Russell
Investments holds both equity and debt in the company across multiple portfolios. Through EO, it was identified by our
public equity emerging markets team and our fixed income team as having high risk. Each team subsequently requested
manager insight into how the specific ESG risks for this holding are assessed and managed.
Both managers shared that they were actively engaging with the company due to its global leadership in the cement industry
and long-term risks and opportunities around sustainability issues. However, our fixed income manager noted the potential
risks to the cement producer of being overtaken by peers who are also demonstrating strong sustainability progress.
Continued monitoring of the company by Russell Investments was flagged by our investment teams.

OutcomeAfter integrating our managers comments into our engagement selection criteria, the Active Ownership Team in partnershipwith both the fixed income and emerging markets listed equity team determined this materials company to be a strong
candidate for engagement. We explore this engagement and its outcomes in the Engagement section of this report.
While EO was first developed and deployed as a tool for sustainably focused equity funds, in 2023 we worked to adapt andextend its application across all asset classes and portfolios, with a particular focus on fixed income enhancements. Our fixedincome portfolio managers assess bond-specific characteristics (e.g., our total market-value exposure, the duration remaining tomaturity, and credit rating) alongside traditional ESG risk metrics (Sustainalytics ESG Rating, ESG controversies, and MSCI
Carbon score) and work with sub-advisers to integrate the risks highlighted.

Russell Investments / Investment Stewardship Report/ 36

Meanwhile, our Private Markets Teams source proprietary ESG reporting and data directly from our sub-advisers. Materials can
include our completed ESG DDQ (Due Diligence questionnaire), the sub-adviser’s ESG policy, and any other ESG reporting, suchas the Institutional Limited Partners Association (ILPA) or Data Convergence Project templates. If ESG risks are identified, ourprivate markets portfolio managers encourage improved ESG practices and/or reporting.
For each Russell Investments managed fund or segregated portfolio, enhanced oversight may result in the following actions forcertain holdings, with consideration of the impact of risks at the total portfolio level:


Reviewing of metrics and the research behind the metrics

Discussion with the sub-adviser supporting the holdingDiscussion with the Active Ownership Team to consider engagement options

Given that we have built proprietary ESG models and undertake our own ESG research, we are not wholly reliant on third-party
providers. We subscribe to a wide variety of data sets from the different providers outlined above, which provide raw
performance data, drawing on analysis of the data and materials produced by our sub-advisers to inform our models andresearch. Further information on the processes in place to ensure service providers support integration of stewardship andinvestments is provided under section 4.4.

Belief 2 - A deep understanding of ESG factors is value adding
Insight and research
We tailor our research to evolve our understanding of sustainability risks and opportunities, and this is reflected in our strategy
development, metrics, and reporting. The research agenda is tailored to address challenges faced by clients as well as an
ongoing commitment to enhance our proprietary ESG strategies. For example, we refined off-the-shelf ESG scores built for awide range of uses, to focus on financially material ESG issues for use in our proprietary ESG strategy. While managing low
carbon strategies, we found that several unintended consequences such as reduced exposure to renewable energy and overall
increase in ESG-related risk were prevalent among simplistic approaches to carbon reduction, so we researched andimplemented enhancements that better aligned with our clients’ objectives including the introduction of a green energy ratio. As
our clients faced regulatory pressure to introduce climate scenario analysis, we performed detailed due diligence on a dozen
climate risk model providers, and onboarded our preferred provider to enable clients across our platform to meet this emerging
obligation. All of these capabilities have been implemented to deliver comprehensive sustainable solutions.

Case study – Enhancing physical climate risk modeling capabilities
To further our work in providing climate-aware solutions, we identified the need to enhance our capabilities in assessing andincorporating physical climate risks into overall financial risk analysis. The assessment of physical climate risk poses a
significant challenge due to its complexity and the lack of standardized methodologies. Thus, we initiated a comprehensive
review process to evaluate physical climate risk providers. The process involved assessing multiple providers based on
criteria such as the sophistication of their methodologies, data quality, track record, and alignment with industry standards.
As well, we launched a project to develop in house GIS expertise and began to develop tools to allow us to visualize thephysical risk exposure of a client’s private real estate portfolio.

OutcomeAfter thorough evaluation and due diligence, we engaged a specialist data provider to help us complete a case study for alarge institutional client. The chosen provider offered advanced modelling capabilities and robust data analytics, enabling us
to enhance our understanding of physical climate risks within the client’s private real estate portfolio.
Furthermore, recognizing the importance of physical risk exposures from a geographic perspective, we invested indeveloping GIS and spatial analysis capabilities. This involved leveraging advanced geospatial technologies to map andanalyze the distribution of physical climate-related hazards such as flooding, sea-level rise, and extreme weather events
across the client’s real estate portfolio.

Russell Investments / Investment Stewardship Report/ 37

Building a sustainable transition universe
Russell Investments began developing decarbonization overlays in 2015. However, our investment professionals recognized thatinvesting in a way that actively contributes to a more sustainable future requires a deeper level of scrutiny and a more careful
application of ESG data than a simple de-risking approach. For clients desiring a systematic overlay, strategies must be tailoredto pinpoint and support businesses and sectors actively progressing towards more sustainable practices, technologies, andoperations.
Thus, we designed a systematic approach to identifying investments that captures a company's positive impact on theenvironment and society while acknowledging the trade-offs between positive and negative outcomes. This “Sustainable
Transition Universe” navigates the complexity of sustainable transformation by applying a multi-faceted criteria set. The highlevel criteria include:Positive Impact Today: We evaluate companies based on their revenues or services linked to Sustainable Development Goals(SDGs) and other positive impact themes.

Emerging Technologies: We consider technologies in development, measured by capital expenditure and patents held.
These technologies are critical for driving sustainable change in the future.



Negative Impact Assessment: We assess companies based on the significance of their negative impact. This isn't about
excluding all companies with negative impacts, as all companies have some level of negative impact. Instead, we focus on
those with a substantial overall negative impact that hinders their potential to contribute positively to sustainability.

The Sustainable Transition Universe truly shines in its ability to be used within multi manager portfolios through our Completion
Portfolio framework. We build sustainability-focused funds while controlling for the potential factor and sector biases that may
materialize at the total portfolio level - all while ensuring that each name held within the portfolio still meets our rigorous
sustainability standards.

Belief 3 - Active ownership is an effective tool for improving investment outcomes
Active OwnershipAs part of our stewardship activities, we aim to engage with companies on overall business strategy, capital allocation, and ESG
practices, while encouraging appropriate levels of risk mitigation in line with our engagement policy. In addition, we promotetransparency to support informed decision making and well-functioning financial markets by engaging specifically on ESG
disclosures. While a number of criteria guide our selection of engagement opportunities, our evaluation of a company’ssustainable risks is couched in its industry context, through the use of peer-relative metrics and qualitative comparisons.
Additional information regarding our proxy voting and engagement actions during 2023, as well as our plans to further
strengthen Russell Investments’ active ownership function going forward, are detailed in the Active Ownership segment, section
5 below.

Belief 4 - Embedding ESG into the firm’s culture improves likelihood of prolonged success
Culture and processes
At Russell Investments, our culture is built on a commitment to a foundational set of beliefs and practices which provide a richcombination of real-world guidance and an over-arching ethic within which we conduct our business. We believe that theeffective integration of diverse ideas and perspectives brings richness to our culture and increases our ability to provide
innovative solutions to our clients, while adding value to our shareholders and community. Please refer to section 1 to learn
more about our purpose and values.

Russell Investments / Investment Stewardship Report/ 38

4.2 Our risk management program

UK Stewardship Code – Principle 4Japan Principles for Responsible Institutional Investors – Principle 1
The New Zealand Stewardship Code – Principle 3

In order to identify threats to financial security and manage them for the benefit of investors and the broader market, we havedeveloped a robust, multi-layered approach to risk identification and response. This approach seeks to stay vigilant to all sorts ofrisks, both operational and financial, as well as formulate careful responses to threats that impact our business, our clients andthe broader market and society.

Identifying and responding to systemic risks: Framework and key elements
At Russell Investments, we operate an independent risk management program through an organizational unit called Global Risk
Management (GRM). Consistent with best practices and regulatory requirements, GRM is independent from both manufacturing
and go-to-market functions.
GRM’s basic framework is to identify, measure, monitor and communicate, along with the supporting concepts of integration,
insight and challenge. Important elements in GRM’s risk framework include:

Risk matrix: The purpose of this matrix is to identify and inventory key risks for each of Russell Investments’ businesses,
along with the drivers of these risks.

Risk measurement: Multiple risk measurements are required in most instances to get a detailed ‘read’ on risks.

Five lines of defense: Russell Investments has adopted a ‘five lines of defense’ protocol to reinforce each associate’s role in
the risk management process. These are (1) Board Oversight, (2) Executive Management, (3) Internal Audit, (4) Risk
Management and Compliance and (5) Business Units. Each of these have established and reinforced responsibilities for theidentification and management of risk.



Risk governance: GRM has implemented a risk governance structure which has been integrated into other Russell
Investments governance structures.



Risk appetite: The idea of a risk appetite must be considered from multiple perspectives because some risks are borne by
Russell Investments and others by its clients. Key dimensions of this are ‘principal versus agency risk’ and ‘buy versus sellside exposures’.



Risk assessment: GRM conducts formal assessments via its annual Enterprise Risk Assessment and targeted risk reviews.
Informal assessments occur continuously. These assessments are used for multiple purposes such as escalation whenappropriate, development of remediation plans and input to the annual audit plan.



Organization and specialization: GRM’s organizational arrangements includes three specialized risk teams: credit,
investment/market, and operational risk. The Operational Risk Team is also responsible for the insurance program andbusiness continuity. Functional teams are supported by several regional associates.

Key risk categories and response mechanisms
Different categories of risk require discrete tools and processes to identify, examine and respond to risks in the course of anevolving market and operating environment. The GRM function is organized around the management of Investment Risk, Credit
Risk, and Operational Risk with appropriate tools, expertise, and attention applied to each, the details of which are explained
below.

Investment risk
The Investment Risk Management (IRM) team measures and monitors market and liquidity risks. IRM operates a granular multiasset enterprise risk system consisting of internally developed, as well as industry leading third-party, market risk models with
IRM-developed proprietary components which extend and enhance the capabilities. Investment Risk is always modelled at the
total portfolio level and not by individual asset classes.
The investment risk process is rooted in risk identification and measurement. Effective evaluation of investment risks involves
assessment across three key pillars:
1.

Market risk: The risk of change in the market value of investments and/or level of earnings due to movements in market
prices. Market risk calculations must consider changes in equity and commodity prices, interest rates, exchange rates,
implied volatilities, and inflation.

Russell Investments / Investment Stewardship Report

/ 39

2.

Exposure measurement: Quantifying exposures across key investment risk dimensions (i.e., country, currency, asset type,
GICS and credit rating) provides a non-model-based view into investment strategy. Investment risk arises when there is amismatch between stated strategy and actual exposures taken.

3.

Liquidity risk: Arises when assets cannot be readily converted into cash and/or without an onerous discount in value to meet
liabilities or other cash needs. Two types of liquidity risks need to be considered:a.

Market liquidity risk is the potential adverse price impact due to illiquidity on a particular security.

b.

Funding liquidity risk is the potential for adverse impacts due to portfolio dealing terms and/or redemption activity(behavior) of an investor.

Credit risk
Russell Investments’ Credit Risk Management Team independently review issuers and counterparties and performs on-going
monitoring of their financial strength. A Rating Committee assigns an internal credit rating to each issuer and counterparty.


Exposure monitoring: Credit Risk Management applies a risk-based approach to monitoring credit exposures. Consistent with
Russell Investments’ five lines of defense, the business unit bears primary responsibility for monitoring and managing credit
exposures.

Governance: An approved list of counterparties and their corresponding internal ratings is maintained and updated asneeded. The results of both the initial and periodic reviews are presented to the Rating Committee. Russell Investments’Credit Risk Management Committee (sub-committee) of Russell Investments’ Global Risk Management Committee ratifies
counterparties and issuers on Russell Investments’ approved list.



Approved list: Russell Investments portfolio managers and traders may only use issuers and counterparties on the approved
list maintained by Credit Risk Management.

Material ESG criteria inform our credit evaluation. For example, our opinion on the fundamental strength of a counterparty
reflects diversification of its business model and considers a company’s ability to sustain itself in the advent of a severe shock
due to environmental related issues. We also consider how well a company manages its relationships with its workforce, thesociety in which it operates, and its political environment. Lastly, in scoring a counter-party’s management team, we consider
the make-up of a counterparty’s board, its strength, independence and its effectiveness of decision making and oversight, andwe address any regulatory, tax or legal violations, among other disclosures. We score more favorably companies that are taking
a proactive role when incorporating sustainable practices.

Operational Risk
Operational Risk Management (ORM) focuses on identifying, assessing, and monitoring operational risks.
Russell Investments uses a multi-element risk identification approach which operates on the premise that the recognition andmeasurement of risk needs to occur on both a proactive and reactive basis. Our long-standing formal escalation protocol
promotes timely communication to senior management, enabling changes (i.e., enhancements to controls) to be made whennecessary. Russell Investments employs a disciplined event capture approach with results reported through the risk governancestructure. Ongoing monitoring, as well as targeted risk reviews and risk profiling, provide a basis for insights as to how risks arechanging in response to market conditions and the evolution of strategy and portfolio composition.


Governance: Russell Investments maintains an Operational Risk Committee which is a sub-committee of the Global Risk
Management Committee. Chaired by the Global Head of Operational Risk, the Operational Risk Committee is responsible forthe oversight of operational risks inherent in Russell Investments’ global businesses and legal entities - including people,
process, technology, third party, regulatory and reputational risks. The Operational Risk Committee and Regional Risk
Committees assist the Global Risk Management Committee in its oversight of Russell Investments’ operational risk
governance structure, operational risk management framework and policies, and operational risk exposure.

Event Escalation: All events are required to be reported to the associate’s manager and Regional Risk Officer in accordancewith the Firm’s global event escalation policy. Depending on the severity and type of event, the escalation process could
include the Global Head of Operational Risk, the Chief Legal Officer, Global Chief Compliance Officer, Chief Operating
Officer, and other Executive Committee members, as well as the CEO. Regulatory and compliance breaches are reported to
the relevant regional compliance officer and regulatory authority, if necessary.

Business Continuity: The Business Continuity (BC) team works closely with global and regional business units to develop
appropriate plans. Each business continuity plan documents key processes and applications and covers recovery time
objectives and alternative procedures in the event of a loss or outage. Each business unit validates its business continuity
plan periodically through a combination of annual review, tabletop scenarios and integrated disaster recovery exercises. The
Business Continuity group provides periodic program status updates to the Operational Risk Committee.

Russell Investments / Investment Stewardship Report/ 40

Enterprise risk assessment
On an annual basis, Russell Investments updates its Enterprise Risk Assessment, which includes a list of market-wide andsystemic risks identified by Russell Investments’ Global Risk Management Team. Each identified event is given a rating across
two dimensions namely likelihood and severity. At year-end 2023 as compared to the prior year, there was no change in the top
risks as identified by the GRMT:

Illiquidity Risk



Policy Exhaustion

Pandemic

Factor crowding investing

Trade-and currency wars

Technological advances

Cold War 2.0

Correlation shock

Climate risk including transition risk and physical risk

Notably, while life feels post-pandemic for many, the contagion remains on the risk list due to the continued mutations in the
spike protein, which current vaccines target.
We continue to improve our understanding of climate change at the enterprise level. In 2023, we expanded our review under the
categories of physical risk and climate risk. Further information in relation to our approach to tackling climate risk is provided in
section 4.3.
Once risks/events are identified, steps are taken to evaluate whether these risks should be monitored and/or mitigated. Where
required, this may include recommending new risk monitoring procedures or changes in portfolios to track or address thepotential impact of the risk.
Climate change is acknowledged as a risk that needs to be considered at the total portfolio/client level and, as such, will be
implemented in Russell Investments’ Enterprise Risk Management System. This implementation will include exposure
information (e.g., carbon footprint) as well as climate scenario analytics capabilities. Further information in relation to ourapproach to tackling climate risk is provided in section 4.3.

Sustainability Risks Policy
Russell Investments’ policy is to integrate sustainability risk management into our investment solutions by identifying, evaluating
and managing relevant risks in our investment manager review process, portfolio management and through implementing
proprietary solutions. We believe sustainability risks are most relevant to investment outcomes when they exhibit financial
materiality and, like all investment risks, are incorporated by balancing expected risk with expected reward. In managing
investment solutions, we consider financially-material sustainability risks in the context of expected rewards using a blend of
inputs from sources including, but not limited to, investment managers, third-party data sources, and Russell Investments’propriety analysis. Furthermore, we incorporate bespoke sustainability risk management and explicit controls based on clients’requirements for customized mandates. As well, we seek to collaborate with our advisory clients to consider, monitor andmanage sustainability risk priorities in their portfolios.
Developing a deep understanding of portfolios’ financially-material sustainability risks and how they are identified is an explicit
objective for all Russell Investments’ portfolio managers. Our process for ensuring this happens, called “Enhanced Oversight”, isdescribed in section 4.1. Portfolio managers leverage our standard sub-adviser review cycles, including annual due diligence,quarterly reviews and other meetings throughout the year, in this process. We also address sustainability risks throughout ourinvestment practices, including our manager research rankings which explicitly assess their ESG capabilities and active
ownership as well as via investment committee governance, which is described in section 3.

Russell Investments / Investment Stewardship Report/ 414.3 Addressing market-wide and systemic risks: climate change

UK Stewardship Code – Principle 7
Japan Principles for Responsible Institutional Investors - Principle 1
The New Zealand Stewardship Code - Principle 3

The challenge
Russell Investments formally endorsed the Task Force on Climate-related Financial Disclosure (TCFD) in 2019 in recognition thatclimate change is a monumental challenge to the global economy and that without reliable climate-related financial information,markets cannot accurately price climate risks and opportunities. Incorporating climate-related risk management strategies into
the financial system is a crucial first step to pricing risk and directing capital flows needed to meet global ambitions for theenergy transition. The recommendations provide a useful and common framework to increase transparency within financial
markets. Our 2023 TCFD Report is available on our website.

Our vision
We pride ourselves on partnering with clients to meet their climate objectives. Through our stewardship programs, and as active
investors, we promote the TCFD’s recommendation for companies to provide effective climate-related disclosures that enable
more informed financial decision making. We advocate for companies to have board-level oversight and governance of climatechange impacts. We also hold ourselves accountable for providing transparency around our own investments and operations. We
are committed to driving progress.

Progress to date
We have made considerable progress incorporating climate change considerations into our business. In our TCFD Report, weoutline key climate-related risks and opportunities and assess them using metrics and scenario analysis in accordance with therecommendations of the TCFD. We share policies developed for formally and systematically addressing sustainability risks anddescribe the evolving practices by which we integrate climate awareness into our investment process. We believe that active
ownership is an important lever for delivering investment outcomes and is also one of the most effective tools at our disposal toeffect change.
Progress to date has included enhancing processes for climate risk and opportunity identification, assessment, and managementin the following ways:

Establishing appropriate governance – Establishing governance around climate risks, including development of a climatechange policy, addition of climate risk metrics to our risk management dashboard, and identification of individuals
responsible for our climate response.

Extending quantitative research – Expanding the depth of our quantitative risk assessment capabilities for transition andphysical risk, including breakdown by channel through a partnership with a climate model specialist.



Policy development – Enhancing the process through which climate risk is managed in portfolios, as detailed in our
Sustainability Risk Policy, which was reviewed and approved by the IDRIC in July 2023 with no material changes. The key
elements of this policy direct investment professionals to leverage data, sub-adviser insights and in-house expertise to
identify and manage sustainability risks.

Active ownership – Engaging with investee companies on the topic of climate change risk and natural capital – with over
50% of our corporate engagements covering environmental issues in 2023.

Solution development – Managing carbon reduction portfolios, as we have done since first launching low carbon strategies
in 2015, with a track record of enhancements to our approach as best practices and data evolve.

In recognition that tackling climate change requires global coordination, we emphasize collaborative action including:

Aligning with other investors to encourage comparable disclosures and consistent regulatory frameworks, which is anecessary step to improving the availability and quality of data.

Engaging collectively with systemically important emitters as a powerful tool for addressing systemic risk. This includes our
support for Climate Action 100+ and other collective engagement channels, as detailed in section 5.1 of this report.



Sharing best practices across industry practitioners to facilitate information sharing and collective knowledge building. This
includes collaborations with, and support for, the Institutional Investors Group on Climate Change (IIGCC) and theTransition Pathway Initiative (TPI), among others. These are described in section 6.3.

Russell Investments / Investment Stewardship Report/ 42

Identification of climate-related risks and opportunities
The first step in managing climate-related risks in investments is identifying them. There are many mechanisms through whichclimate-related factors impact security prices, but these risks can be broadly categorized as transition or physical risks. We
recognize that different risks are likely to manifest over different time horizons and that they require different tools to assess, as
outlined below.

Exhibit 19: Snapshot of the climate risk identification and assessment process
RISK OR OPPORTUNITY IDENTIFIEDDESCRIPTION

EXAMPLES OF ASSESSMENT TOOLSMOST RELEVANT TIME HORIZON

Transition Risks & opportunities

Risks arising from shift to low carbon
economyScenario analysis (esp. transition
scenarios), metrics

Medium term

Changes in cost

Price on carbon, costs of abatement

Carbon footprint metrics

Short and medium term

Changes in demand

Demand destruction and creation
arising from shifts in demand

Scenario analysis (esp. transition
scenarios), metrics on green
revenues or climate solutions,
exposure to potentially stranded
assetsShort and medium term

Physical risks can be event driven(acute) or longer-term shifts (chronic)
in climate patterns

Scenario analysis, (esp. hot house
world scenarios)Long term

AcuteIncreased severity of extreme
weather events

Scenario analysis (esp. hot house
world scenarios), asset-level risk
mapping

All but increasing severity long term

Chronic

Changes in weather patterns, risingtemperatures, rising sea levels

Scenario analysis (esp. hot house
world scenarios), estimatedsensitivity to productivity impacts,
heating/cooling days

Medium and long term

Physical Risks

Climate risk is characterized by a longer time horizon than many traditionally managed risks. To make this more explicit, werefer to short-to-medium-term horizons, in the climate context, as a three-to-ten-year horizon, and a long-term horizon as theperiod out to 2050, although we note these are rough approximations only.

Assessment and management of climate-related risks and opportunities
On an annual basis we provide an assessment of our global portfolio against metrics and scenario analysis in accordance withthe recommendations of the TCFD. Following identification and assessment of climate-related risks and opportunities, we turn tomanagement. Portfolio managers are the first line of defense in managing portfolio risks, and management of climate risk is nodifferent. We believe embedding deep expertise and awareness of sustainability risk within investment teams is key to fully
integrating climate management into our process. This is formalized in our sustainability risk policy, as described in section 4.2.
In addition to a formal policy, our climate risk management practices continue to evolve. This includes our enhanced oversightand active ownership programs, where climate-related considerations play a pivotal role.
Supplementing these firm-wide practices, we continually enhance our approach to carbon-managed portfolios for clients andfunds that want to build in more explicit climate-related outcomes. For a subset of clients and funds, we set and manage toforward-looking net zero targets. Taken together, we adopt a multi-layered approach to managing climate issues including
formal policies, practices, engagement and carbon managed portfolios and target setting.
Despite considerable progress, we know this is the beginning of a long journey for our organization and the global investmentcommunity at large when it comes to tackling climate risk in portfolios. Most immediate on our horizon remains our commitment
to the Net Zero Asset Managers’ Initiative. Our commitment involves rapidly raising knowledge across teams, building new
capabilities, and setting ambitious targets around what it means for our portfolios to be aligned to a net zero by 2050 objective,
always with a client-first, fiduciary focus. We are expanding our coverage of active managers with a focus on climate
considerations and sustainable strategies more broadly, and we continue to seek out data sets that provide valuable insight into
the climate exposures of our portfolios.

Russell Investments / Investment Stewardship Report/ 43

Exhibit 20: A multi-layered approach to our climate response: key pillars

Source: Russell Investments.
Please refer to our annual TCFD report for additional details on how we identify, assess, and manage climate-related risks andopportunities.

Russell Investments / Investment Stewardship Report/ 44

4.4 Our approach to monitoring service providers

UK Stewardship Code – Principle 2, 8
Japan Principles for Responsible Institutional Investors - UK Stewardship Code – Principle 8
The New Zealand Stewardship Code - UK Stewardship Code – Principle 4

Our multi-manager business strategy requires the oversight and monitoring of external asset managers that we employ in ourinvestment portfolios. We also rely on third-party providers to support our active ownership practices. Furthermore, we count on
a host of additional third-party vendors to ensure the overall efficiency of our core services for clients. A description of how wehold each of these three categories of service providers accountable is provided below.

External managers
Due diligence on external managers prior to their inclusion within our funds and portfolios is conducted at two levels by
specialist teams that are independent of each other:Manager research analysts who sit within the Investment Division (ID) and evaluate and monitor from an investment
perspective, and

The Global Manager Oversight and Due Diligence (GMODD) group within the Global Risk Management (GRM) function,
which is independent of the ID.

We believe that it is important from a risk and compliance perspective to separate the operational due diligence function, which
reports up to our Chief Operating Officer, from the investment due diligence function, which reports up to our Global Chief
Investment Officer. This separate, operational review is particularly pertinent within alternative and unlisted asset classes, suchas hedge funds and private market investment strategies, where transparency is lower.
The combination of our investment research and our operational due diligence research on managers aims to achieve objectives
and minimize negative surprises for our clients. We have had success in avoiding managers that have exposed investors toheadline risks. A description of each type of research is provided below.

Manager research due diligence
Russell Investments has an experienced team of approximately 37 analysts engaged solely in the manager research process.
Each year, our research analysts conduct approximately 1,800 research meetings and conference calls with investment
managers. These evaluation sessions are our primary means of gathering information to arrive at an informed opinion about amanager's product(s). Our assessments, gained from multiple sessions over time, allow us to establish an overall opinion of theorganization and its investment strategies. Our analysts are responsible for pre-meeting analysis of the product (meeting
preparation that includes a historical review of prior meetings and analysis of the strategy) and for conducting the researchmeetings. Analysts supplement these meetings with regular contact with managers in their universe, through phone calls, emails
and less formal update meetings as required.
As part of our evaluation process, we conduct a qualitative and quantitative assessment. We score managers against a detailed
framework that captures the key inputs to a robust investment process, and we undertake quantitative analysis of each strategy’s
performance patterns, attribution and outcomes. A sampling of the inputs can be described as the following:

Russell Investments / Investment Stewardship Report/ 45

Exhibit 21: A qualitative and quantitative evaluationQUALITATIVE ASSESSMENT
Organization

Stability, ownership, and incentives

Team

Dynamics, diversity, and motivation

Experience

Skill and stability of personnel

Capital markets case

Conceptual basis for philosophy

Research

Depth and alignment

Decision making

Accountability and efficiency

Security Selection

Use of security-level characteristics

ESG

Insights, portfolio implementation, and active ownership

QUANTITATIVE METRICS
Portfolio construction

Effects of portfolio turnover

Consistency with philosophy

Magnitude of risk assumed/tracking error

Stability through time

Sources of relative performance

Ability to manage sizeable accounts

Liquidity analysis

Absolute and risk-adjusted performance vs. broad manager universe

Style indexes

Source: Russell Investments. For illustrative purposes only.
In addition to the above factors, we have identified a variety of proprietary attributes of successful managers that are unique togiven styles of management. Analysts are charged with making relative assessments of managers within their respective styles,
to better discriminate among manager choices. The results of our manager research efforts are captured in our global
proprietary database, RADAR, which we believe is one of the largest and most comprehensive manager tracking databases in theworld. Developed in-house, RADAR is our primary repository for research reports generated on the products of investment
managers globally and includes over 14,000 current manager products.

Russell Investments / Investment Stewardship Report/ 46

Case study – Annual manager ESG due diligence questionnaire
Since 2014, Russell Investments has requested information from high-interest external investment managers on the
integration of responsible investing practices into their investment processes. For calendar year 2023 and for our subadviser managers, this took the form of a Due Diligence Questionnaire (DDQ) with enhanced emphasis on understanding
and overseeing their stewardship activities. The ESG DDQ results provide a supplementary source of information about howeach asset manager approaches ESG issues and responsible investing, serving as reference points for our research analysts
when evaluating investment strategies.

OutcomeOur DDQ covered a range of topics from commitments including net zero target setting and the United Nations Principles
for Responsible Investing (UNPRI), to product trends, reporting, and stewardship outcomes for both engagement and proxyvoting. Responses represented 80% of our funded managers.
Throughout 2023, we saw the strengthening of reporting requirements in Europe, Canada, and Australia, as well as the riseof a more contentious debate in the United States. For our managers, top challenges cited to integrating sustainability
information into investment decision making included 1) the missing or poor quality of data received from corporates and 2)
meeting diverse client needs and expectations.
Nevertheless, over half of our managers noted the dollar value of their sustainable investing AUM grew from 2022 to 2023.
Managers also responded that environmental issues continue to be the biggest concern voiced by clients – suggesting thatsustainability will continue to be a lasting force in the investment landscape.
Additional key insights from the FY23 ESG DDQ are detailed below.

Manager Resourcing
Across our sub-advisers, 68% have full-time dedicated responsible investing professionals with most resources being
dedicated to a specific sustainability team, a stewardship team focusing on policy, proxy voting, and engagement activities,
or within an equity-specific team.

Manager Responsible Investing Commitments and Net Zero
Complementing our own commitments, many of our sub-advisers have also joined sustainability-related organizations andinitiatives with the majority (over 75%) having signed on to the UNPRI. When it comes to reporting specific initiatives,
almost 50% support TCFD reporting, with 29% reporting via CDP, 20% reporting to the International Financial ReportingStandards for Sustainability, and 16% reporting to the Global Real Estate Sustainability Benchmark.
More than 30% of our managers are signatories to the Net Zero Asset Managers Initiative and have made the commitment
to support a net zero by 2050 goal. In line with this, we saw 27% of our sub-advisers engage through the Climate Action
100+ network and over 5% engage with companies through the Nature Action 100 network.

Sustainability Products
Over the past 12 months, our sub-advisers saw the most growth and/or interest from clients in ESG-integrated products
followed by specific thematic mandates. Where our sub-advisers offer impact strategies, the majority focus on the energy
transition followed by strategies aligned to the Sustainable Development Goals (SDGs), and lastly social impact strategies.

Sustainability Integration
In 2023, reducing risk was still the most cited driver of ESG-driven investment decision making. Governance concerns werereported as a driver 40% of the time, followed by climate risk and social risks at 35% and 33% respectively. Of our subadvisers, only 5% noted that ESG factors do not drive investment decisions, a steady annual decline from the 22% whochose that answer in 2021.

Russell Investments / Investment Stewardship Report/ 47

Case study – Annual manager ESG due diligence questionnaire
Active OwnershipOver 80% of our sub-advisers actively engage with management of their corporate holdings to discuss sustainability issues.
Collaborative engagement remains an important tool for investors to utilize when engaging with holding companies as over
60% of our sub-advisers note they’ve partaken in collaborative engagement with other investors.
When engaging with corporate holdings, governance topics were of highest importance for our sub-advisers in conversations
followed by climate change specific risks or opportunities, and finally human capital management issues. Our sub-advisers
did not limit their outreach to corporate holdings; over 40% engaged with policy makers as part of their responsible investing
approach.
After conducting engagements, 74% of managers established sustainability related objectives and outcomes which were
documented and monitored. If an engagement was deemed unsuccessful, over half of our managers indicated that they have
utilized adverse proxy voting (i.e., a vote against management or a vote for a shareholder resolution) and written
communication as a tool for escalation with 37% divesting from companies where the engagement had failed.

Global manager oversight and due diligence
The Global Manager Oversight and Due Diligence (GMODD) team’s operational due diligence (ODD) review involves evaluating
the business, compliance and operational risks and controls of third-party managers that may materially impact Russell
Investments, our funds and clients. A thorough ODD review is based upon discussions with key principals and employees of the
manager; observations of their business practices; and an appraisal of various documentation and representations disclosed by
the manager. When conditions allow, an on-site meeting in the office is also optimal. The key areas analyzed include:

Operational risks – it is important to examine the manager’s trade processes, from execution and counterparty oversight tosettlement and reconciliation, along with guideline compliance, allocation policies, and cross trades. This area also includes
an analysis of the manager’s soft dollar and directed brokerage policies and its resolution process for trade and operational
errors.



Business risks – ODD reviews a firm’s business structure and vendor oversight, strategic planning processes (includingorganizational growth) governance, management oversight and supervision, along with the firm’s IT infrastructure andbusiness continuity planning.

Compliance – a review of this area considers the firm’s compliance monitoring and reporting, personal trading policies, gifts
and entertainments and conflict of interest policies, compliance with regulatory agencies, personal information security, andrecord retention.

ODD involves a different skill set to that which is needed for performing investment due diligence. We believe that it is best
conducted by professionals with strong backgrounds in global regulations, trading, operations, and business risks. The outcomeof an ODD review can have clear Red or Green flags - but may in practice sit in an Amber area. In formulating an opinion, theODD reviewer will consider:Consistency – were all the documents and verbal assertions consistent with each other and all the relationship confirmations
consistent with expectations?

Transparency – did the manager provide documents in a timely way and allow access to the key people and systems during
the on-site visit? Were the reviewers allowed an open dialogue with the firm’s service providers and referees?

Firm infrastructure – does the firm have a tight control environment with sufficient systems and knowledgeable support staff
to support the products they are managing?

Manager reputation – did all the background checks come back clean and with all references confirmed?

Absent clear Red flags where an ODD review will recommend that an investor avoid allocating funds to a specific money
manager, an investor may still decide to invest with a manager with some deficiencies. The value of the ODD report is that theinvestor is aware of these deficiencies and is able to monitor them and work with the money manager to increase their controls
in the areas where specific weaknesses have been identified.
ODD is not a new concept. We have built a global team of analysts dedicated to conducting reviews of the risks outside ofmanagers’ investment capabilities. These analysts follow our Manager Compliance and Operations Review (Manager CORE)
process, helping shape the way Russell Investments ranks money managers and the decisions for recommending, hiring, or
terminating managers.
Russell Investments / Investment Stewardship Report/ 48

ODD can help investors to understand the additional risks to money managers’ businesses beyond the investment risks, ensuringa more holistic assessment of managers’ capabilities. ODD is not just a process to be followed when hiring a manager. We
undertake reviews of these risks on an ongoing basis, as a manager’s business evolves.

Case study – A 2023 operational due diligence review
In the second half of 2023, the GMODD team conducted an on-site operational due diligence review with a private equity
manager. Where deficiencies are found, based on tested ODD criteria, recommendations are provided as well as assistanceto address the identified issues.

OutcomeThis review identified two items which resulted in sub-section ratings of “Weak,” and as a result the GMODD team maderecommendations to address the inadequacies. The “Weak” rating was attributable to two specific practices. First, themanager engages expert networks but had not implemented compliance oversight of interactions with the expert networks.
The GMODD team recommended that the manager institute compliance oversight on a sample of these interactions toaddress material non-public information/insider trading risks. Secondly, the manager’s Valuation Committee includes only
Investment team personnel, with membership identical to the Investment Committee. The GMODD team recommended
making changes to the composition of this committee, as the Valuation Committee should include qualified non-investment
personnel to offer some level of independence. The manager agreed to consider implementing these changes.

Active ownership
In order to deliver effective stewardship, Russell Investments relies on third-party data providers, including Sustainalytics andproxy adviser Glass Lewis. The primary services we receive are detailed in the diagram below.

Exhibit 22: Details of service providers
SERVICE PROVIDERSERVICE RENDEREDHOW THIS SERVICE CONTRIBUTES TO RI'S ACTIVE OWNERSHIP

Glass, Lewis & Co

Viewpoint Voting Platform

Allows Russell Investments to monitor a very high volume of voting activity andplace manual votes when appropriate.

Application of Custom Proxy Voting Guidelines

Glass Lewis applies a bespoke set of Proxy Voting Guidelines created andmaintained by Russell Investments’ Active Ownership Committee.

Resolution research and analysis

Russell Investments’ internal proxy analysts draw on Glass Lewis' research andanalysis as one of several resources when preparing a recommendation for the
Active Ownership Committee on a referred item. For more information onreferred items, please see Section 5.2.

Coordinate collaborative engagement partnership

Sustainalytics coordinates and leads engagement activities; Russell Investments
participates in Sustainalytics' Thematic engagements, please see Section 5.1.

Company-level ESG ratings and analysis

Our investment professionals leverage Sustainalytics’ ESG risk ratings andanalysis in our manager due diligence, in portfolio management andconstruction, and in our engagement practice.

Sustainalytics

Source: Russell Investments. For illustrative purposes only.
To ensure our process of delivering effective stewardship is of high standard, we regularly monitor and review the services ofboth Glass Lewis’ and Sustainalytics’.
For proxy voting, the annual service review includes sampling and statistics from the previous year’s vote activity to measure theaccuracy and timeliness of the Glass Lewis research team. Russell Investments tracks these statistics year-on-year to ensure
consistent quality of service. Members of the Active Ownership Committee also hold an annual meeting with Glass Lewis,
addressing any concerns or updates regarding the services they provide.
Russell Investments has partnered with Sustainalytics as an engagement service provider because their model allows for close
oversight and integration with our internal active ownership and investment processes. Our Active Ownership Team, under theoversight of the Active Ownership Committee, is responsible for the selection and monitoring of engagement themes. The teamcommunicates regularly with Sustainalytics on the positioning of these themes, target company selection and on progress andoutcomes. Additionally, portfolio managers and wider members of the ID regularly participate in direct company engagements
led by Sustainalytics.

Russell Investments / Investment Stewardship Report/ 49

Other third-party vendors
As a global organization, Russell Investments has longstanding experience of integrating with various internationally recognizedoutsourcing vendors and partners, alongside our internal resources, to improve the overall efficiency of our core services forclients. We engage with providers across our operational, information technology and financial service lines, for some of our
middle and back-office support services. We maintain continuous oversight of our providers via service level agreements, formal
relationship meetings and evaluations that incorporate performance metrics.
We utilize third-party providers for middle-back-office services such as administration services for our pooled funds,
custodian/depository services, portfolio accounting, and certain IT services. Three primary service providers we engage with aredescribed below.
State Street – We have a long history of working with State Street globally, since 1995 in EMEA. State Street provides allfund administration (including fund accounting), prospectus and regulatory guidelines monitoring, andcustodian/depository services for Russell Investments.



SS&C Globe Ops – SS&C Globe Ops provides portfolio accounting services, including daily reconciliations of cash andpositions when comparing our current holdings with the custodians’ data.



CGI – As a proportion of IT support functions are outsourced, Russell Investments’ dedicated global IT Applications andInfrastructure department works in conjunction with CGI to provide IT infrastructure, including IT support and security.

Russell Investments’ vendor risk management framework utilizes a combination of decentralized vendor management,
centralized risk management, and focused sourcing and procurement. Key components to managing vendors include business
unit ownership of vendor activities, sourcing and procurement assistance, and risk management oversight.
Within Russell Investments’ business units, assigned resources provide primary selection, monitoring and oversight of key
vendors, such as management of service levels and the identification and mitigation of service issues. These efforts are the ‘firstline of defense’ to mitigate vendor risks and identify areas of service improvement. For example, Global Operations (FundServices, Investment and Data Operations) works directly with key service vendors (custodians, trading counterparties, reporting
providers, etc.) daily to manage fund and client investment activities. During the initial selection and onboarding process, thefirst line activities include consultation, as needed, with subject matter experts such as Legal, IT, Compliance and Operational
Risk Management as part of Russell Investments’ vendor due diligence process. Assigned vendor owners review and follow up
on any relevant findings or issues noted in key vendor controls documentation such as SSAE 18/SOC 1 reports. Other activities
include tasks such as vendor performance monitoring, continuous improvement reviews, event management and analysis, andquality assurance. Onsite visits (if required) are periodically performed with key vendors to review operations and to assess
performance as necessary.
As a second line of defense, Global Risk Management operates a Third-Party Risk Management program that provides enterpriselevel oversight for the firm’s designated critical vendors. Control activities facilitated in conjunction with first line business units
include assessment of vendor SOC reports, IT posture via vendor security assessment questionnaires, and vendor business
continuity and (4th party) oversight programs. The program also conducts ad-hoc targeted due diligence in response to specificwidespread events, such as cybersecurity events impacting a large number of firms or geopolitical events that potentially impact
service providers. Governance of the program is directed by the Operational Risk Committee with assistance from othercommittees depending on the type of vendor and risks involved.

Russell Investments / Investment Stewardship Report/ 50

Case study – An unnamed vendor review in 2023
Our review of a critical vendor’s control environment in 2023 found that the vendor’s independent external auditor provided
a “Qualified” opinion indicating that a control was not in place to provide a reasonable assurance that lockbox items were
processed completely and timely. Russell Investments Global Finance team conducted an investigation and as a result wereassured that Russell Investments was not impacted by the missing lockbox control.

OutcomeRussell Investments’ Global Finance, Global Risk Management, and Global IT (“Russell Investments review team”) reviewed
the vendor’s response to the missing control indicating the primary issue was minimal staffing at the lockbox processing
centre and the inability of the vendor to provide an audit report detailing the timestamp for each step in the process. The
review team found the vendor’s response, including adding new processes and procedures to validate, track, and trace
lockbox operations were appropriate.

Global Sourcing and Procurement
Starting in 2022 and following a review of systems that would allow us to analyze vendor spend data alongside metrics ondiversity, our Global Sourcing and Procurement team implemented a product from Supplier.io, called Supplier Explorer. The tool
identifies supplier diversity metrics within our existing spend data and allows us to search for other diverse suppliers as well.
Utilization of that tool in 2023 resulted in a 45% increase in the number of vendors that meet the classification of diverse
provider and a 51% increase in spending with Women Business Enterprises (WBEs). The tool has also helped establish abaseline for reporting and transparency. We are a member of the Financial Services Roundtable for Supplier Diversity giving us
access to further benchmarking and learning about best practices that are specific to our industry. We continue to evaluate
additional memberships with groups that certify, develop, and connect Minority Business Enterprises (MBEs) with major
corporations and public agencies.

Russell Investments / Investment Stewardship Report/ 51

5. Active Ownership

UK Stewardship Code – Principles 9Japan Principles for Responsible Institutional Investors - Principle 1, 3, 4
The New Zealand Stewardship Code – Principle 2, 4

5.1 Our engagement approach
Active ownership is an important component of our investment responsibilities and decision-making process. As part of ourstewardship activities, we aim to engage with companies on overall business strategy, capital allocation and responsible
investing practices, while encouraging appropriate levels of risk mitigation. Furthermore, through ongoing dialogue, we canbetter understand both the risk factors and potential return associated with the ownership of a company. Through ourengagement activities, we aim to promote changes by encouraging good practices on material issues that may protect andenhance long-term sustainable value creation and shareholder rights, and ultimately benefit our clients as the beneficiaries of
our investments.
Our business model and service capabilities enable a multi-channel approach to stewardship, meaning that we engage directlywith issuers, engage through and with our sub-adviser partners, and join collaborative engagement efforts with third-party
market participants. Further information can be found in our engagement policy.

Exhibit 23: Impactful ownership practices

Source: Russell Investments, for illustrative purposes only.
As a leading investment solutions partner with multi-asset and multi-manager capabilities, we leverage a broad set of
relationships, including those with our sub-adviser partners, to exert influence and enable multiple levels of engagement. These
Russell Investments / Investment Stewardship Report/ 52

relationships extend across and through our sub-advisers, external standards setters, proxy and engagement service providers,
other market participants and, of course, corporate issuers. These connections also provide information sharing and serve as animportant feedback loop into our active ownership and investment processes.

Russell Investments-led engagements
A strong stewardship program includes pursuing activities which offer the highest return or risk mitigation opportunities. To thisend, Russell Investments’ Active Ownership strategy is focused on material issues under the general categories of ESG. While
we recognize that a broad set of issues are worthy of shareholder attention, we believe that identifying a select set ofengagement priorities supports accountability and successful outcomes.
Internally led, direct company engagements are initiated by two key methods:
Intentional selection of portfolio companies identified as high ESG risk through various data resources. Further described in
the engagement selection criteria below.

From our proxy voting activity – We may engage with management in advance of an AGM, or instances where we havevoted against management may lead to a follow-up engagement. Some of these votes are determined by our custom
guidelines; others are referred to the Active Ownership Committee for special review. The proxy voting section below
provides additional information on referred items and the manual voting process.

Sub-adviser partner engagements
Given our position as a multi asset manager-of-managers, we leverage our relationships with our sub-advisers to provide an
informed and integrated approach to active ownership. Sub-advisers are hired to play targeted, value-enhancing roles in our
portfolios. Day-to-day they are routinely in close contact with our investee companies, with over 80% of sub-advisers noting
they regularly meet with management to discuss ESG issues (per the FY2023 ESG DDQ). Therefore, it is natural that theirinsights and recommendations regularly contribute to our engagement and voting processes.
We consider our sub-adviser relationships to be a strategically important element of our stewardship program. Wheneverpossible, our portfolio managers solicit input from our sub-adviser partners in the selection of our engagement priorities.
Discussions with our sub-advisers can validate the benefit of an engagement and inform our approach. Through consultation
with our sub-adviser partners, we determine whether joint outreach or separate but aligned efforts are more likely to beeffective. Opportunities highlighted by our sub-advisers might result in partnered engagement efforts, in Russell Investments-led
engagements with sub-adviser input, or in reinforcement of engagement efforts that are already underway. In all scenarios, wehave an opportunity to amplify the strategic input of our sub-adviser partners to the holding company.

Collaborative engagements

UK Stewardship Code – Principle 10
Japan Principles for Responsible Institutional Investors – Principle 3, 4
The New Zealand Stewardship Code – Principle 4, 7

Russell Investments leverages third-party engagement initiatives to extend our reach across regions and markets. In 2023, we
utilized Sustainalytics engagement offering alongside our memberships with the Climate Action 100+ initiative, Net Zero
Engagement Initiative (NZEI), and Nature Action 100 initiative. More information on our collaborative engagement efforts isprovided below.

Sustainalytics
Since early 2020, Russell Investments has leveraged a partnership with Sustainalytics for thematic and collaborative
engagements. Sustainalytics’ engagement programs enable participants to build relationships with a selected set of issuers toencourage action on specific issues in ways that promote long-term value. In the second half of 2023, Sustainalytics restructured
their collaborative engagement channels, beginning a shift from “thematic subscriptions” to broader themes for engagement.
The new approach targets a larger selection of companies for engagement, as well as evolving the processes to allow forengagement beyond the three-year timeline that was previously in place. The new structure supports third-party industry
initiatives and stewardship codes. Russell Investments is continuing our participation through selected topics that align with ourengagement focus areas as defined in the engagement selection section below. Russell Investments’ collaboration with
Sustainalytics has materially broadened our scope of engagements particularly in emerging markets, where it can be difficult toinitiate engagement conversations with companies. Across all four themes selected, our investment professionals participate
directly in calls with the targeted companies.

Russell Investments / Investment Stewardship Report/ 53

Exhibit 24: Thematic engagement through Sustainalytics in 2023

Source: Russell Investments, for illustrative purposes only.

Climate Action 100+
Russell Investments recognizes climate change as a threat to the global economy and the financial security of our clients, and weparticipate in investor collaborations that support our efforts to mitigate this threat and deliver strong financial outcomes. One of
the largest is Climate Action 100+, an investor initiative launched in 2017 to encourage companies to improve governance andstrengthen climate-related financial disclosures and transition plans. As members of the Climate Action 100+ initiative since
early 2020, Russell Investments has engaged with a selected number of companies on climate transition to support theinitiative’s goal. Our efforts with the initiative are paralleled by 27% of our funded sub-advisers who are also participants in the
Climate Action 100+ initiative, showcasing the value the initiative can have in expanding our active ownership program.
Russell Investments is actively involved as a participating member, taking the lead on a select number of engagements andprioritizing the protection of our clients' interests as our primary focus. We directly and indirectly engage with 170 companies,
making it a meaningful component of our active ownership program. Climate Action 100+ participation has allowed us more
efficient access to these companies and allowed the companies to be responsive to a wider number of investors. During 2023 wehave actively contributed to the working groups with respect to companies we engage with.

Russell Investments / Investment Stewardship Report/ 54

Case study – Repositioning our leadership within Climate Action 100+Engagement Channel
Country of Incorporation
Market Cap
Asset Class
SectorCollaborative Engagement
United Kingdom$8.7bnFixed Income & Public Equity
Utilities

In 2021, Russell Investments joined the collaborative engagement via CA100+ as a Lead Investor for a UK-based oil and gas
distribution company which is classified as one of the 100 largest emitting companies globally.
As co-lead of the engagement, we had regular dialogue with the company as it considered how to improve its approach toclimate change. Moreover, we sought updates on the company’s public policy activities and lobbying alignment disclosure.
We have found the company to be very constructive and open to engagement on climate change risk.

OutcomeAfter careful consideration, and in acknowledgment of the company’s strong commitment and intentionality in its journey
toward achieving net zero emissions and considering that our primary sub-adviser raised no concerns regarding thecompany's decarbonization strategy, Russell Investments decided to step down from its co-lead role in 2023 and redirect our
stewardship efforts toward other leadership positions we hold. Our shift in focus emphasizes our commitment to engaging
on the highest risk and return opportunities across our investment portfolio, thereby benefitting our clients.

Net zero engagement initiative
The NZEI launched formally in March 2023 and aims to extend investor engagement beyond the CA100+ focus list. The aim is toinclude more companies that are heavy users of fossil fuels, thus exposing these companies to risks due to the transition to a
low-carbon economy. The initial target is focused on 107 high-emitting companies in Europe with plans to expand the scope ofengagement targets after the initial phase. These companies are engaged by more than 90 investors with the goal of providing
more transparency to the company’s climate transition plan.

Nature Action 100
Estimates suggest that more than 50% of global GDP is dependent on nature and, therefore, exposed to risks relating tobiodiversity loss and natural resource degradation. Nature Action 100 is a global investor engagement initiative mobilizing
institutional investors to establish a common high-level agenda for engagements and a clear set of expectations to drive greater
corporate ambition and action to stem nature and biodiversity loss. Investors participating in the initiative are engaging with 100
companies in key sectors deemed to be systemically important in reversing nature and biodiversity loss by 2030. Russell
Investments joined Nature Action 100 at its launch in 2023 as a co-signatory of the letter sent to the targeted companies. Initial
engagement actions are scheduled to take place in early 2024. With our participation in Nature Action 100, we aim to contributeto the transition toward a more sustainable and resilient global economy for the protection of our clients' interests.

Engagement selection
At Russell Investments, we hold thousands of securities on behalf of our clients. Our engagements are conducted with consistent
application of our processes across geographies, sectors and market cap. However, given the breadth of our investment
operations and clients’ interests, we leverage data and research to focus our efforts on the highest return or risk mitigation
opportunities. The time horizons of these engagements are aligned with our clients’ requirements as detailed earlier in thisreport.
Russell Investments considers the following criteria when selecting targets for engagement:

Russell Investments’ ownership stake, as percent of shares outstanding and/or weight of fund exposure;Proxy voting history and management responsiveness to shareholder concerns;Material ESG analysis performed in-house and by third-party vendors of ESG metrics focusing on sub-industry peer
comparison and ESG-related controversies;Research and analysis from Glass Lewis, our proxy voting administrator;Any history of previous engagement activity; andRussell Investments / Investment Stewardship Report

/ 55



Opportunities highlighted by our sub-advisers.

Engagement targets are finalized using the input and insights of our portfolio management teams via processes approved byRussell Investments’ Investment Strategy Committee.

Engagement focus areas
In addition to the criteria outlined above, we centre our engagement activities around six focus areas, listed below. These havebeen chosen in consideration of:1.

Our business purpose of addressing our clients’ most pressing financial challenges,

2.

Clients’ expectations collected from surveys and communication,3.

Our proxy voting and engagement practices through time,4.

Our corporate values and purpose, and5.

Our responsible investing beliefs.

Our engagement focus areas are monitored and updated as required to address regulatory developments, emerging investment
risk and opportunities, and clients’ requests and needs. More information on this approach can be found in our engagement
policy.
We expand on the financial materiality of these focus areas and provide relevant case studies beginning on page 70 of thisreport.

Exhibit 25: Engagement focus areas

Source: Russell Investments, for illustrative purposes only.

Russell Investments / Investment Stewardship Report/ 56

ESG Disclosure
Russell Investments encourages companies to publicize how they are addressing material ESG issues relevant to their businesspractices in a timely manner. To this end, we promote the publication of an integrated or standalone sustainability report on anannual basis, which provides information in line with peers and industry good practices.
For most small market capitalization and emerging market equity holdings, we expect ESG disclosure to be the main
engagement topic. We recognize that these companies have a disadvantage compared to their larger or developed market peers
due to resource constraints and the financial burden that comes with measuring and disclosing ESG risks. Our advocacy forsmall cap and emerging market holdings therefore often starts with improving ESG disclosures.

Case study – Improving ESG disclosure at a small cap company
Engagement Channel
Country of Incorporation
Market Cap
Asset Class
SectorRussell Investments-led
United Kingdom$1.1bnPublic Equity
Materials

Russell Investments engaged for the second time with a UK-based chemicals company that operates globally. After an initial
engagement on the topic of increased disclosure in 2022, the company demonstrated some progress by reporting astrategic, integrated approach to sustainability. However, Russell Investments held a follow-up engagement in 2023 toencourage higher transparency around the actions the company is taking to meet its stated targets. We requested that thecompany to disclose metrics and specific targets relating to its sustainability goals. In our view, the lack of disclosure ismaterial because it obscures key aspects of its risk profile and operational performance. Clear disclosures support theevaluation of the long-term viability and resilience of the business while insufficient disclosure can erode investor trust andinterest.

OutcomeRussell Investments will continue to engage with the company. While it has invested in addressing ESG risks within its
business, we aim to see the opportunities from this strategy reflected in the company's growth. Furthermore, we will expect
more transparency and specificity in their next annual report.

United Nations Global Compact
Established in 1999, the United Nations Global Compact (UNGC) is a voluntary framework consisting of ten principles focusedon human rights, labor standards, the environment, and anti-corruption. These principles promote the integration of sustainablebusiness practices and challenge companies to become more open and transparent about their strategies, policies, andprocedures related to sustainability issues. The UNGC has grown into the largest corporate sustainability initiative in the world.
To ensure that companies meet a minimum standard for good governance practices, we check whether a company has breachedglobal 'norms', as represented by the UN Global Compact Principles. The Russell Investments Global Exclusions Committee(GEC) monitors our holdings for breaches of the UNGC Principles and oversees any actions that are taken as a result. If a
company is identified as being in breach of one of the principles of the UNGC, we consider the company a high-priority
engagement target. Our goal is to understand why a breach has been flagged, promote improvements in governance practices,and ultimately assess whether the company exhibits good governance.

Russell Investments / Investment Stewardship Report/ 57

Case study – Mitigating potential human rights violations
Engagement Channel
Country of Incorporation
Market Cap
Asset Class
SectorRussell Investments-led
United Kingdom-Australia
GBP 83.79bn
Public Equity
Diversified Metals Mining

Russell Investments engaged with a global diversified miner to ensure the company complies with the international norms
and standards such as Global Compact’s internationally recognized principles for business conduct, ILO Conventions, andthe OECD Guidelines for Multinationals Enterprises.
The company is facing some challenges in its operations due to the presence of numerous protected rock shelters in thearea. The company expressed efforts to avoid blasting near these sensitive sites. In the past, similar events had a profoundmaterial impact on the company, influencing its stakeholder relations and operational strategies. It led to reputational
damage, affecting investor confidence and brand reputation.

Outcome
The company has recognized the need for potential revisions in blasting management techniques and the acknowledged thecomplexity of balancing operational needs with environmental and cultural preservation concerns. Russell Investments willcontinue to engage with the company to ensure we are comfortable with how the company is addressing human rights
impacts.

Engagement tracking and escalation

UK Stewardship Code – Principle 11
Japan Principles for Responsible Institutional Investors - Principle 3, 4
The New Zealand Stewardship Code - Principle 4, 7

Tracking
Our Active Ownership Team, in coordination with the relevant portfolio management team, is responsible for monitoring andrecording the status of company progress for each engagement action, including the relevant focus area and the aim of eachoutreach. Engagements are ‘ongoing’ as long as we believe progress can be made. Ongoing activities include early-stage
conversations that result in raised awareness, as well as companies that have moved toward implementation of a revised
strategy. While we do not subscribe to an explicit time frame for escalating or closing our internally-led engagements, we expect
and plan for most issues to be resolved over a three-year period.

Russell Investments / Investment Stewardship Report/ 58

Exhibit 26: Tracking engagement progress

Source: Russell Investments, for illustrative purposes only.
Engagements and outcomes are reviewed at least annually, and members of the Active Ownership Team are charged withrecommending whether an engagement should be escalated, finalized, or closed - typically in consultation with relevant AOC
members or investment colleagues. When a company repeatedly fails to respond to our outreach and/or does not advance along
a path toward implementation, the Active Ownership Team may recommend escalation activity to the AOC.
Escalation
At Russell Investments, being an active owner is an important component of our investment responsibilities and fiduciary duty.
We are a long-term shareholder across thousands of securities on behalf our clients, and we engage knowing our clients should
benefit over the longer-term. Our engagement approach is to encourage risk mitigation on the most material risk or return
opportunities through building mutually beneficial long-term relationships with investee companies. We believe that ongoing
dialogue is likely to be more effective than divestment or exclusion see that as a fundamental part of our responsible investing
strategy.
We have several avenues for escalation, including enhanced dialogue with our sub-advisers and other market participants that
result in coordinated or collaborative engagements, sharing concerns in writing (publicly or privately), and/or adverse proxyvoting on related items. Regardless of engagement status, we challenge and monitor our sub-adviser partners on thesustainability risks of their holdings on a regular basis, assessing their insight and analysis to ensure strong oversight.
As a global investment solutions provider, we seek to maintain a broad investible universe that provides the greatest scope for
identifying excess return opportunities and diversified portfolio positioning.
We believe that in many circumstances there are better alternatives to managing risk and sustainability outcomes than outrightexclusion, and we adopt a multi-disciplinary approach to managing sustainability risks, as detailed in our Sustainability Risks
Policy.3 Where appropriate, exclusions are used to meet client preferences, manage risk, or to deliver on strategy objectives.
When using an exclusion, we strive to employ a thoughtful approach to calibrating criteria so as to meet complex topics such asenergy transition with a holistic approach, meaning identifying companies whose business models are at risk as well as thoselikely to contribute to real-world solutions.

Russell Investments / Investment Stewardship Report/ 59

Exhibit 27: Escalation strategies

Source: Russell Investments, for illustrative purposes only.

Case study – Escalation to sub-adviser due to poor governance practices at a controlled
company
Engagement Channel
Country of Incorporation
Market Cap
Asset Class
SectorRussell Investments-led
France$14.5bn
Public Equity
Industrials

Russell Investments expects companies to follow governance good practices for the market they operate in, including
remuneration benchmarked versus peers and transparency into pay structure. Further, controlled companies are encouraged
to have at least one third of their board constituted by independent directors.
Russell Investments engaged for a second time with a French aerospace and defense company, focusing on its governancepractices as well as environmental and social strategies. Ultimately, the company is below peers in integrating reasonable
governance practices - even considering it is a controlled company. The company has no remuneration committee on theboard and all remuneration decisions are made by one individual.

OutcomeDuring this engagement, the company showcased their response to shareholder requests to integrate ESG issue
management into remuneration. While this demonstrated they are willing to work with shareholders, they were unwilling toincrease transparency into remuneration. Russell Investments escalated the engagement to vote-against-management at the2023 AGM due to the company’s continued indifference toward shareholder opinions on board independence and executive
remuneration.
In addition to voting against the company’s remuneration scheme, Russell Investments has also escalated the engagementby communicating the outcome of our conversations to our sub-advisers, flagging this as a material governance risk.

Russell Investments / Investment Stewardship Report/ 60

Engagement across asset classes
Fixed Income
The fixed term and contractual nature of bond investments afford bondholders a finite number of engagement opportunities tomake explicit impact with individual issuers. In most instances, these opportunities are brief in duration, occur before an
investment decision must be made, are not open to all parties, and are offered at the discretion of the issuer’s willingness toengage. However, repeat and frequent bond issuers have a greater incentive to listen to bondholders.
Russell Investments leverages a multi-avenue engagement approach for its fixed income holdings alongside equity
engagements. This results in direct engagements with corporate fixed income holdings as well as our monitoring of sub-advisers
engaging with issuers. As bondholder engagement has become a key source of information for assessing ESG-related risk andreturn opportunities in the marketplace, we actively use these activities to gain greater insight into underlying companies orentities, improve corporate transparency, and influence business practices.
In 2023, Russell Investments expanded its Enhanced Oversight processes to incorporate fixed income holdings, a challenging
process due to the nature of the securities and lack of data. In our assessment, we consider bond-specific characteristics
alongside traditional ESG risk metrics. This includes our total market-value exposure, the duration remaining to maturity, andcredit rating. Combined, these metrics are used to evaluate the downside ESG risk an issuer may be presenting within our
portfolios. See section 4 above for more information.
The Enhanced Oversight process has led to an increase in the number of Russell Investments-led, fixed-income specificengagements. Due to our broad equity exposure, we may conduct these in tandem with our equity teams; however, the focus of
the conversation will be more focused on improving risk management practices as opposed to sustainable opportunities. Pleasesee below for more in-depth case studies of our fixed income specific engagements.
At the same time, we maintain oversight of the responsible investing awareness and capabilities of our underlying managers,
including their efforts toward engagement. Our sub-adviser due diligence framework incorporates an assessment of the leveland quality of ESG integration and active ownership across all asset classes, including fixed income. Consideration given in thisprocess includes, but is not limited to:How managers prioritize engagement activities;How engagement objectives are set;

Who is involved in the engagement activities;

How the progress is monitored;How engagement activity success is measured; and

Publication of product or asset class specific sustainability reports.

Based on our monitoring activities, our sub-advisers are increasingly exercising proactive engagement in the context ofmateriality and industry and company-specific risks, but the frequency and nature of the conversations can vary depending on
the credit quality of the issuer. More information regarding this process can be found in the section 4 above.
Investment-grade corporate bond issuers are, by definition, companies with higher credit ratings resulting from healthierfinancial conditions. Such companies are often large in size, listed on the stock market, and employ dedicated investor relations
personnel to address investor concerns. Therefore, the transparency of the investment-grade bond issuers tends to be greaterthan that of the below-investment-grade bond issuers. As such, although we have seen a substantial expansion of engagement
efforts among below investment-grade bond managers (such as high-yield managers), engagement activities are moreestablished among sub-advisers with investment-grade corporate bond mandates.
Depending on market conditions, high-yield issuers potentially have a greater incentive to listen to potential investors’ needs, as
their ability to access capital markets is less certain than that of investment-grade companies. There are also more privatecompanies in the high-yield market than in the investment-grade corporate market, and private companies often lacktransparency, such as visibility into the composition of board members. While our high-yield managers were alreadycommunicating with the management of underlying companies and their stakeholders, this dialogue is shifting to include
broader ESG-related questions. Our high-yield managers also focus on increasing transparency and influencing corporate
behaviors, to improve the long-term enterprise value of the company. At the same time, our sub-advisers are increasingly
focusing on their engagement activities around climate risk.

Russell Investments / Investment Stewardship Report/ 61

Case study – Fixed Income engagement on natural capital management
Engagement Channel
Country of Incorporation
Market Cap
Asset Class
SectorRussell Investments-led
Canada$26.4bn
Fixed Income
Chemicals

Russell Investments continued its engagement with the company following an initial discussion in 2022 to increase its
disclosures of metrics, targets, and overall strategy regarding climate change resilience and natural capital management.
Given the company’s role as an agricultural-chemical provider, it must consider both emissions-reduction strategies andopportunities for natural capital and biodiversity management by collaborating with growers. We found that the company
has significantly advanced the integration of sustainability strategies and disclosures through improved annual reporting.
However, there is still room for improvement, especially concerning measurements and targets for Scope 3 emissions
reduction.

OutcomeThe disclosures made and targets set by the company showcase a logical approach to managing its natural capital risks. We
will continue to monitor how the company succeeds in tracking biodiversity metrics and the expected expanded targets
aimed at reducing adverse impacts.

Case study – Fixed Income engagement on natural and human capital
Engagement Channel
Country of Incorporation
Market Cap
Asset Class
SectorRussell Investments-led
Mexico$12.3bn
Fixed Income
Materials

Russell Investments engaged with a company involved in production, distribution, marketing and sale of cement and otherglobal construction materials to encourage the company to identify the natural capital impacts and/or dependencies that are
relevant to their business and long-term strategy. Furthermore, we aimed to confirm the robustness of the human capitalmanagement of the company.
From a materiality perspective the efficient utilization of human capital ensures smooth operations, innovation, and quality
control throughout the production and distribution processes. Secondly, natural capital, particularly access to raw materials
like limestone and clay, is essential for cement production, and sustainable management of these resources is critical for
long-term viability and environmental compliance.

Outcome
While we are broadly satisfied with the board's oversight of the human capital strategy from a governance perspective, there
appears to be a challenge with the monitoring of third parties, particularly regarding road accidents, which may compromise
the company's commitment to achieving its target of zero fatalities by 2025. Biodiversity impact is also an area that needs
development. The company will be setting targets and is currently in conversations with the Science Based Targets Network(SBTN) to establish science-based targets. They expect to have the targets verified within the next year. Russell Investments
will continue to engage with the company with a particular focus on natural capital management, as the company isdeveloping its strategic approach to these issues.
Private Markets
Over the past decade the level of sophistication of private market funds has increased significantly. In this context, and as a
private market investor, Russell Investments recognizes that active ownership, combined with the ability to ensure strong
execution in individual portfolio companies, is increasingly important to realizing value.
Russell Investments / Investment Stewardship Report/ 62

Private Markets is a diverse asset class that includes a wide range of different strategies such as venture capital, growth equity,and buyouts, as well as indirect strategies such as fund of funds and secondaries. Different sub-asset classes and funds will havedifferent exposures to ESG-related risks and opportunities. Therefore, a ‘one-size-fits-all’ approach to active ownership is rarely
deployed consistently across an entire portfolio, or even throughout the life cycle of a particular asset.
To overcome the challenges associated with this asset class, and to ensure we execute on fulfilling our duties as an active owner,
we employ the following mechanisms for active ownership in private markets:Good Governance: Governance is crucial in this asset class because it is very difficult to adjust the terms of ownership after
the initial investment. Hence, governance practices and requests are discussed upfront, while thinking about the long-term
relationship with the manager.



Limited Partner Advisory Committee (LPAC) seats: Where possible, we try to gain LPAC seats to provide additional transparency,
and for smaller investments we aim for ‘observer status’. Private markets can be very opaque; these interactions enhance
the transparency we receive for our investors.

Voting: We actively participate on voting items. Adjustments to documentation that require LPAC or investor approval canoccur regularly due to, for example, new investors or adjustments to Key Person provisions.

Engagement and Monitoring: Given that data in this market is not readily available, insights gained through regular engagementwith managers and other investors is the best source to improve transparency. Using side letters to require and encourage
disclosure and reporting on material ESG issues is another important tool used in this process.

Case study – Private Equity partnership governance engagement
Engagement TypeCountry of Incorporation
Sub asset

Negotiation of proper “key person clause” in Limited Partnership Agreement
United Kingdom
Buyouts – European lower middle market

Russell Investments engaged with a company involved in production, distribution, marketing and sale of cement and otherglobal construction materials to encourage the company to identify the natural capital impacts and/or dependencies that are
relevant to their business and long-term strategy. Furthermore, we aimed to confirm the robustness of the human capitalmanagement of the company.
From a materiality perspective the efficient utilization of human capital ensures smooth operations, innovation, and quality
control throughout the production and distribution processes. Secondly, natural capital, particularly access to raw materials
like limestone and clay, is essential for cement production, and sustainable management of these resources is critical for
long-term viability and environmental compliance.

Outcome
While we are broadly satisfied with the board's oversight of the human capital strategy from a governance perspective, there
appears to be a challenge with the monitoring of third parties, particularly regarding road accidents, which may compromise
the company's commitment to achieving its target of zero fatalities by 2025. Biodiversity impact is also an area that needs
development. The company will be setting targets and is currently in conversations with the Science Based Targets Network(SBTN) to establish science-based targets. They expect to have the targets verified within the next year. Russell Investments
will continue to engage with the company with a particular focus on natural capital management, as the company isdeveloping its strategic approach to these issues.

Russell Investments / Investment Stewardship Report/ 63

Case study – Re-electing independent directors
Engagement TypeCountry of Incorporation
Sub asset

Election of independent directors – LPAC member
Singapore
Asian core open-end real estate fundOur sub-adviser recognized the importance of maintaining strong governance practices and sought investor consent for key
board appointments. This included the re-election of two independent directors to ensure continuity and uphold the integrityof the board. Additionally, the sub-adviser proposed the election of a third independent director to replace an outgoingmember, thus ensuring a diverse and skilled board composition capable of effectively overseeing the fund's operations andsafeguarding investor interests.

Outcome
Independence stands as a cornerstone of sound governance principles, ensuring objectivity and accountability within
decision-making processes. Recognizing this fundamental value, Russell Investments supported the election and re-electionof independent directors. By doing so, Russell Investments reaffirmed its commitment to upholding the highest standards ofgovernance, thereby fostering investor confidence and trust in the integrity of the board's oversight. This endorsement
further underscores Russell Investments' dedication to promoting transparency, fairness, and responsible stewardship acrossits investment activities.

Case study – Private Equity Fund Extension
Engagement TypeCountry of Incorporation
Sub asset

Fund Term Extension– LPAC member
United Kingdom
UK Close-end opportunistic real estate fundOur sub-adviser manager approached the Limited Partner Advisory Committee seeking approval to extend the fund term by six
months. This extension was necessitated by deferred payments resulting from the sale of the fund's interest in a corporate
entity. The decision to seek approval underscored the manager's commitment to transparent communication and prudent
financial management, ensuring that all stakeholders were informed and consulted regarding the fund's operations andstrategic decisions. This proactive approach aimed to mitigate potential uncertainties arising from the deferred payments andto safeguard the interests of the fund's investors.

OutcomeAs a member of the Limited Partner Advisory Committee (LPAC), we were asked to approve this extension. Since the fund
was no longer charging investment management fees, our sub-adviser manager proposed that overheads of the fund-specificgeneral partner entities would be borne by the partnership during the extension period, up to a specified cap. Russell
Investments found the proposal to be reasonable and approved the extension.

Russell Investments / Investment Stewardship Report/ 64Engagement activity in 2023
At Russell Investments, engagements are dialogue undertaken to understand, influence and/or improve business practices anddisclosures. As a result of our active ownership development and efforts, during the reporting year we held 510 engagementswith 263 different equity issuers.

Our engagements related to environmental topics:

Climate Change
Resilience

52%
48%

Natural Capital

Environmental

61%

Our engagements related to social topics:
28%

Diversity & Inclusion

72%

Human CapitalSocial13%

Our engagements related to governance topics:
Board Composition &Accountability

49%

Executive
Compensation

51%
24%

Other*

Governance17%* Identifies topics outside our engagement focus areas (proxy vote-related, capital allocation,
related party transactions, and share capital structure)

Russell Investments / Investment Stewardship Report

ESG Disclosure

UNGC

8%

1%

/ 65

Engagement by avenue
Russell Investments occupies a privileged position in terms of industry influence and reach which creates multiple avenues forengagement. Our active engagements encompass Russell Investments-led engagements where we are solely responsible forbuilding agendas and tracking engagement outcomes, as well as those conducted in partnership with our sub-advisers.
Through third-party initiatives, Russell Investments supports collaborative outreach as detailed above (the CA100+, NZEI, andSustainalytics). Due to the structure of these initiatives, Russell Investments leads only a select number of conversations, while inothers, we contribute to agenda building and knowledge sharing. The breakdown of our involvement between third-party
collaborations is detailed in exhibit 29.

Exhibit 28: Engagement channels - active engagement

1% 2%
3% 2%

15%

31%

33%

15%

Russell-Led: Environmental

Russell-Led: ESG Disclosure

Russell-Led: Governance

Russell-Led: Social

Co-Leading Climate Action 100+

Sub-Adviser Partnership: Environmental

Sub-Adviser Partnership: ESG Disclosure

Sub-Adviser Partnership: GovernanceSource: Russell Investments, data as of December 31, 2023.

Exhibit 29: Engagement channels – influence through third-party collaborations

0%

10%

20%

30%

40%

50%

Sustainalytics

60%

CA100+

70%

80%

90%

100%

NZEI

Source: Russell Investments, data as of December 31, 2023.

Russell Investments / Investment Stewardship Report/ 66

Engagements by sector
At Russell Investments, we recognize the importance of materiality, and we seek to evaluate how companies are managing
material ESG factors that also impact financial performance. For this reason, we support the Sustainability Accounting Standards
Board (‘SASB’) standards as a fundamental way for companies to communicate financially material sustainability information toinvestors in an industry-specific and comparable way. In the same manner, we use SASB standards to identify sector-specificpriority issues for corporate engagement.
In line with the breadth of our engagement strategy, during 2023 we engaged with companies across 88 different sub-industries.
Almost one quarter of the engagements conducted over the reporting period were with companies in the materials sector,
followed by Industrials and Energy.

Exhibit 30: Percentage of engagement by sector

Materials

24%

Industrials

17%

Energy16%

Utilities

11%

Consumer Staples

10%

Consumer Discretionary

9%

Financials

5%

Health Care

3%

Information Technology

2%

Real Estate1%

Communication Services

1%
0%

5%

10%

15%

20%

25%

30%

Source: Russell Investments, data as of December 31, 2023.

Russell Investments / Investment Stewardship Report/ 67

Engagement by region
Because we are a global firm, our active ownership strategy has wide geographic reach. In the last two years, through ourpartnership with Sustainalytics, we increased our engagement activity with companies in emerging and other markets where we
had limited activity in the past, particularly the Japanese market. Across all our engagement channels in 2023, we held
engagements with companies in 36 different markets, across seven main geographic regions:Exhibit 31: Engagement distribution by region

26%

Canada &United States

42%

9%

EuropeAsia ex-Japan

11%
Japan

3%

Latin America &Caribbean

3%

Africa & Middle East

5%

Oceania

Source: Russell Investments, data as of December 31, 2023.

Russell Investments / Investment Stewardship Report/ 68Engagement outcomesA crucial part of Russell Investments’ engagement process and a key part of our stewardship responsibilities is tracking the
progress of corporate action and measuring the impact of our engagement activities.
In 2023 while reviewing the status of on-going engagement activity, we determined that 14% of the companies we engaged withhad resolved the issue(s) positively. Furthermore, over three quarters of these companies with objectives that remain on-goinghave shown a clear appreciation of the concerns we raised and have committed to address the issue or are already developing astrategy to do so. We believe our efforts and oversight are a contributing factor to many of these positive developments. We notethat only a small proportion of the ongoing engagements have been closed due to an unsatisfactory response from the company.

Exhibit 32: Breakdown of engagement outcomes

Source: Russell Investments, data as of December 31, 2023.

Russell Investments / Investment Stewardship Report/ 69

Activity across our focus areas
Climate change resilience
Russell Investments recognizes that climate change is one of the defining global challenges of our time and, therefore, a material
investment issue that crosses regions and industries. Our policy is to research, measure, report and consider climate change risk
and opportunities as an integral part of our investing practice, our active ownership, and our business operations to mitigate theimpact of climate change-related risks.
Russell Investments has been an official supporter of the TCFD since 2019, and we promote its recommendation that companies
provide effective climate-related disclosures to enable more informed financial decision making. In addition, we advocate forcompanies to have board-level oversight and governance of climate change impacts. Finally, Russell Investments expects
companies to explain how they have incorporated climate-related issues into their business, strategy, and financial planning –including the disclosure of key metrics and risk management processes.

Case study – Encouraging the development of a strategic transition plan
Engagement Channel
Country of Incorporation
Market Cap
Asset Class
SectorSub-adviser partnershipUSA$73.9bn
Public Equity
EnergyIn 2023, Russell Investments, in partnership with our sub-adviser, conducted an initial engagement with a global energy
equipment and services firm that mainly works with oil and gas operators. The primary goal of the conversation was toencourage the company to create a transition plan that includes short- and medium-term actions to support its strategic
ambitions. We also requested improvement of its climate-related financial disclosures.
We discussed the company’s transition plan, encompassing its short- and medium-term strategies aimed at reducing
carbon emissions across various scopes. This plan focused on transition technology, which the Company recognized as anopportunity for growth. The company expressed its intention to release more detailed disclosures in its next sustainability
report, which will also include improved CDP disclosure.

Outcome
The company’s plans for expanded disclosure represents a positive development that can provide investors with valuable
insights into its sustainability performance and risk management practices. Russell Investments plans to continue
engaging with the company in partnership with our sub-adviser following the release of the company’s sustainability
report in the first half of 2024.

Russell Investments / Investment Stewardship Report/ 70

Natural capital management
Measuring and valuing natural capital can enable companies to better manage the natural resources that contribute to economic
development and growth. Better understanding of the mechanisms that link ecological systems to human wellbeing is required
to assess both the value of benefits from natural resource systems, as well as the expenditure required to maintain thosebenefits. Russell Investments believes that companies should display an understanding of their environmental resource usage
across their businesses and demonstrate responsible environmental management aimed at maintaining the long-term availabilityof assets. As well, we expect companies to implement sound and sustainable environmental practices across their operations
and supply chains to protect against material and reputational risks which can arise from the mismanagement of natural capital.
Initiatives and policies that avoid and/or reduce deforestation are an area of focus for Russell Investments. We advocate fordisclosure as a starting point. In addition, for companies with material biodiversity exposure, and/or those which operate innatural resource-constrained regions, we seek policies on restoration, preservation, and efforts to control any soil and watercontamination.

Case study – Managing natural resources risk in the supply chain
Engagement Channel
Country of Incorporation
Market Cap
Asset Class
SectorRussell Investments-led
Japan$2.7bnFixed Income & Public Equity
Consumer Discretionary

Russell Investments engaged with a Japanese automobile components company which operates on a global scale. The
company is exposed to significant risk from natural capital management, given their reliance on natural resources including
water and rubber in their supply chain. We encourage companies to disclose metrics related to nature-related risks andopportunities based on dependencies and impacts, and to showcase how the organization integrates such risks into theoverall risk-management approach.
Since our initial engagement, the company has expanded its capacity to assess sustainability specific risks and opportunities
by increasing the resources that support its sustainability-related working group structure. However, the company'sorganization of ESG-related documentation is a hindrance to good shareholder communication of its strategy and approach.

Outcome
The company is working to enhance its supplier assessments to include climate, nature, and human capital metrics. By
integrating these metrics, the company aims to better understand and mitigate potential risks associated with its supply
chain, ranging from environmental vulnerabilities to social and labor issues. Russell Investments acknowledges thesignificance of this initiative and will maintain ongoing engagement with the company as it evolves its supplier selection andretention strategy to include natural capital metrics.

Russell Investments / Investment Stewardship Report/ 71

Human capital management
Human capital management is a critical component in company performance. It determines how companies attract, develop, andretain employees while providing working conditions that stimulate greater employee engagement. Human capital is material
across all companies; hence we expect companies to provide meaningful and comparable disclosure in this area. Moreover,research shows that the relationship between diversity on executive teams and the likelihood of financial outperformance has
strengthened over time2. The most diverse companies are now more likely than ever to outperform less diverse peers on
profitability.
While human capital is perpetually important, an increasingly tight labor market has led to a greater focus on employee
recruitment, retention, and inclusion. Furthermore, societal emphasis on gender, racial and ethnic equity continues to grow; weaddress this as a separate focus area given its significance.

Case study – Improving Health and Safety Practices
Engagement Channel
Country of Incorporation
Market Cap
Asset Class
SectorRussell Investments-led
Canada$27.6bn
Public Equity
Metals & Mining

Russell Investments engaged with a mining company domiciled in Canada. The dialogue was focused on the company's
efforts around human capital management, climate change resilience, and natural capital management. The company has arobust ESG report and is consistently transparent with stakeholders. However, recent and consistent controversies andevents showcase that the company's strategy needs to be adjusted to prevent further negative impacts on the business and asubsequent shift in strategy (and reporting) may be required. The company has had five on-the-job deaths since December
2022 and is focusing on overhauling its health and safety practices to meet its target of zero fatalities.

Outcome
The company plans to hire a third-party auditor to assess its health and safety programs, with the results expected in early2024. They aim to make the report available to investors. The expected release of the audit report to investors in early 2024
reflects the company's proactive approach to communicating its efforts in this critical area and building trust withstakeholders. Russell Investments recognizes the importance of prioritizing health and safety practices within companies, as
they not only safeguard employees but also contribute to operational efficiency and long-term sustainability. As such, we arecommitted to continuing our engagement with the company to support its endeavors in enhancing health and safety
practices.

2"Diversity wins: How inclusion matters". (2020, May 19). McKinsey & Company. Available here:
https://www.mckinsey.com/featured-insights/diversity-and-inclusion/diversity-wins-how-inclusion-matters#

Russell Investments / Investment Stewardship Report/ 72

Diversity, equity, and inclusion
There is ample evidence, and it is globally accepted by way of empirical research, that diversity is aligned with good governanceand that it helps to create long-term shareholder value. Russell Investments promotes diversity as a valuable tool to enable highperforming teams and strong business outcomes, and we advocate for greater diversity disclosure. This includes basic workforce
statistics, ethnic and cultural diversity, and details on policies. Russell Investments sees lack of disclosure as a barrier forinvestors who want to assess a company’s culture and a deterrent for the wider workforce and potential employees of a company
who want to understand an employer’s approach to equity and inclusion. Workers want to know their efforts will be recognized
and fairly rewarded. Companies should demonstrate how they are recruiting, promoting, protecting, and retaining a diverse
workforce.

Case study – Japanese Board Diversity and Executive DEIEngagement Channel
Country of Incorporation
Market Cap
Asset Class
SectorRussell Investments-led
Japan$3.4bnPublic Equity
Financials

Russell Investments engaged with a regional bank located in Japan, to discuss improvements in board independence andgender diversity at the board and management levels.
While compliant with the Japanese Corporate Governance code, the company does have room for improvement especiallycompared to global practices. At the board level, just 9% of directors are gender diverse, and while the company indicated it
maintains internal targets and a strategy to increase female board diversity, it was not yet comfortable sharing the plan withinvestors. When asked about how the company is promoting a culture of inclusion and how it supports female managers tomaintain a work-life-balance, the company was unable to provide a satisfactory answer besides noting it does train
employees on DEI areas.

OutcomeRussell Investments would like the company to demonstrate significant cultural improvements regarding its DEI practices
and transparently provide retention rates of females across management levels. Due to the low diversity on the board and inmanagement, as well as the perceived attitude toward DEI practices, the Active Ownership Team recommended that the
Active Ownership Committee consider voting against the Chair of the Nomination Committee at the next AGM.
Russell Investments aims to schedule a call with the company ahead of the 2024 AGM to communicate our intention andgather a response.

Russell Investments / Investment Stewardship Report/ 73Board composition and accountability
The board of directors is the focal point of corporate governance. Directors represent the shareholders, and they are charged
with safeguarding investors’ interests. The board should promote the long-term best interests of the company by acting on an
informed basis, with good faith, care and loyalty. This helps to ensure the effectiveness of the directors in promoting successfulcompanies, thereby generating sustainable value creation for investors while having regard to other stakeholders.
At Russell Investments, we expect companies to have foundational governance structures that promote accountability,
responsibility, transparency, responsiveness, diversity, and independence from company management.

Case study – Ensuring appropriate governance structures are in place
Engagement Channel
Country of Incorporation
Market Cap
Asset Class
SectorRussell Investments-led
United States$394.33bn
Fixed Income & Public Equity
Diversified Banks

Russell Investments engaged with a financial holding company based in the U.S., to request the company to split up theroles of the CEO and Chair of the board. Splitting the roles of chair and CEO is material as it enhances corporate
governance by introducing a system of checks and balances, reducing the risk of conflicts of interest, and promoting
independent oversight.

OutcomeIn acknowledgment of the substantial support garnered at the AGM for the separation of the CEO and Chair roles, thecompany has made a firm commitment to enact this change upon the CEO's departure. A succession plan has already been
set in motion, with the CEO slated to assume the chairmanship role for approximately one year to facilitate a seamlessleadership transition. Following this interim period, an independent chair will be appointed to the board, aligning with bestpractices in corporate governance and enhancing board oversight and accountability. This proactive approach underscores
the company's dedication to responsive governance and ensures continuity and effectiveness in its leadership structure. We
are satisfied with the response received, and no further action is needed.

Russell Investments / Investment Stewardship Report/ 74

Executive compensation
Russell Investments believes executive compensation should align the interests of a companies’ management with those ofshareholders. Programs should offer clear and transparent disclosure, coupled with basic fairness in the use of shareholders’capital to retain and incentivize management. Inappropriate and poorly designed remuneration structures have been acontributing factor to excessive and imprudent risk taking by individuals. Hence, we regularly engage with companies to ensurethat remuneration packages effectively align the interests of the executive directors, the workforce, and shareholders with thecompany’s strategy and performance achieved.

Case study – Compensation accountability
Engagement Channel
Country of Incorporation
Market Cap
Asset Class
SectorRussell Investments-led
Australia$7.7bnPublic Equity
Industrials

Russell Investments engaged with an Australian transportation infrastructure company during its compensation road show
to address the negative outcomes from the 2023 AGM. The board attributed much of the dissent to a semi-controversial
acquisition, which has since demonstrated strong performance. They believe that increased disclosure will foster positive
sentiment among shareholders for the 2024 AGM.
The company plans to reconfigure the equity plan to incorporate relative total shareholder return (TSR) metrics andoperational cash flow, expanding the metrics to two. Additionally, they intend to extend the vesting period to four or five
years. We see the proposed changes as an improvement in the compensation package.

Outcome
The company has clearly responded to shareholder feedback and is working to enhance transparency around
remuneration reporting and compensation structure to better align with shareholder interests. Russell Investments will
monitor the remuneration report before the 2024 AGM for the anticipated changes to ensure the company follows throughon its commitments. We will reach out to the company before the AGM if these changes are not reflected in the reporting.

Russell Investments / Investment Stewardship Report/ 75

5.2 Proxy voting

UK Stewardship Code – Principle 12
Japan Principles for Responsible Institutional Investors - Principle 1, 5, 6
The New Zealand Stewardship Code - Principle 2, 5

For 30 years, Russell Investments has executed a robust, global proxy voting program that is a foundation for our stewardshipefforts. Russell Investments has documented Proxy Voting Policies and Procedures and maintains custom Proxy Voting
Guidelines. Our Guidelines are a bespoke set of rules and policies, based on industry best practices and regulations that dictate
how to vote on certain topics. Russell Investments’ Guidelines are carefully drafted to result in votes that promote the bestinterest of our clients, and, at least annually, our Guidelines Sub-Committee reviews and updates them to remain aligned withshareholders’ best interests. The Voting Guidelines address most proxy issues with detailed specificity; however, the Active
Ownership Committee (“the Committee”) recognizes some issues require more scrutiny and a non-prescriptive approach. In
those instances, the Guidelines refer the votes to the Committee for review. Our committee members are among our mostexperienced investment professionals around the globe.
As our external proxy administrator, Glass Lewis, is responsible for aggregating proxy ballots received directly from Russell
Investments’ custodians and for applying our custom Guidelines when executing proxy votes. Russell Investments’ internal
proxy coordinator monitors our voting activity via Glass Lewis’ online platform and directs any proposals that require case-bycase review to internal proxy research analysts, who in turn provide a recommendation to the Committee based on individual
and proxy administrator-provided research. The majority of proposals voted on by Russell Investments do not require case-bycase review – Glass Lewis applies our Guidelines directly. To ensure that Glass Lewis casts votes in accordance with our
Guidelines, the Committee oversees an annual internal audit process to verify the accuracy of vote execution.
Our Proxy Voting Guidelines are available to review in their entirety on our Responsible Investing site here.

Impact of 2023 guidelines updates
As described above, the Guideline Sub-Committee’s annual review of our Proxy Voting Guidelines allows the Committee toremain abreast of regulatory updates and industry trends. Two amendments to the Proxy Voting Guidelines that were
implemented for the 2023 proxy season made a considerable impact on our voting activity:Time Commitment of Directors


Following a review of the efficacy of the over boarding threshold before the 2023 proxy season, the Committee voted toadjust our approach to over boarding, so that our default stance is to oppose the election of a non-executive director
who serves on the boards of more than four publicly traded companies. If the candidate is also an executive director ofa publicly traded company, the number of board seats allowed (outside of the company for which the candidate serves
as an executive director) is reduced to two.



As a result of this update, our rate of voting against directors for over boarding significantly decreased year-over-year
and was no longer the primary driver of votes against directors. This marks an improvement from our approach in2022, where we found that our over boarding policy did not allow enough flexibility for directors who also served as
executives at external companies.

“Say on Climate” PolicyManagement sponsored “Say on Climate” proposals emerged as a new channel for investor engagement in climatechange strategies during 2021. We believe these votes can drive better carbon disclosures, encourage more credible
climate strategies and enhance shareholder engagement; however, we are also wary of unilaterally supporting theseresolutions, given that shareholders could approve plans with emission targets or strategies that prove inadequate in
the future. Companies might then try to avoid updating those plans in future years by anchoring to the fact that theyreceived shareholder approval.

We expect companies to provide a level of transparency that allows investors to better understand how they may be
impacted by climate-related risks and opportunities, and how they have embedded climate change into their strategy.
We evaluate management-sponsored votes on climate plans and reports on a case-by-case basis, and we may consider
several factors, including but not limited to the governance of the vote, the materiality of climate risk to a company
compared to its peers, and any information gained from our engagement activities and/or sub-adviser input.

Russell Investments / Investment Stewardship Report/ 76

Looking ahead: 2024 guidelines updates
For the 2024 proxy season and as per annual practice, the Committee refined our Guidelines to enhance Russell Investments’consideration of various risks, practices and strategies, as well as to increase the efficiency of the voting process.

Case study – Annual Proxy guidelines review
In the fourth quarter of 2023, Russell Investments' Active Ownership Committee undertook a comprehensive review anddrafted updates to our Proxy Voting Guidelines. This initiative reflects our ongoing commitment to enhancing ourstewardship practices and aligning them with evolving market trends and best practices. Through this process, we sought
to ensure that our voting guidelines remain robust, relevant, and reflective of our core principles and values.

OutcomeIn addition to revising our policies, the Committee approved the reformatting of the guidelines document to provide a
concise summary of Russell Investments’ stance on key proxy topics. This new format offers a high-level overview of eachissue. We trust this new format demonstrates transparency and accountability in our stewardship activities. It provides
clients and stakeholders with insight into the principles guiding our voting decisions on behalf of our investment
portfolios.
The 2024 version of Russell Investments Proxy Voting Policy can be found here.
The responsible investing landscape is constantly changing, and Russell Investments aims to keep pace with the regulatoryenvironment. Beyond refining the guidelines concerning ESG shareholder proposals, the Committee ratified amendments for the2024 proxy season, including but not limited to:Updated voting policy on board diversityRegulations promoting board diversity are increasingly recognized as vital for fostering inclusive decision-making andenhancing corporate governance practices worldwide. These regulations aim to ensure that boards reflect the diverse
perspectives of society, including gender, ethnicity, age, and background. Through mandates or guidelines,
governments and regulatory bodies encourage companies to embrace diversity at the highest levels of leadership,promoting fairness, equality, and representation in corporate settings.

While at Russell Investments, we consider the specificities of each market, we have had a threshold-based approach toboard-level gender diversity for the last two proxy seasons. We vote against the chair of the nominating committee ofthe board of a blue-chip developed market company outside Asia that is not at least 30 percent gender diverse.
Following analysis of the proposals where Russell Investments voted against a nominating committee chair in 2023, we
found that there were several instances where the nominating committee chair that we had opposed based on this rule
was in fact a gender-diverse director.



The committee determined an update was appropriate, as voting against the election of a gender-diverse director underthe existing guideline was inconsistent with the intention of the rule.



As a result, we have amended the guideline going into the 2024 season – where a given board does not meet the 30%
threshold for gender diversity, but the chair of the nominating committee is gender diverse, Russell Investments will
vote on a case-by-case basis.

Streamlined approach to remuneration policies and reports.


Russell Investments has historically applied a customized set of proxy voting guidelines for over a decade. These
guidelines, initially developed with a region-specific focus on remuneration, have evolved over time. In 2024, after
careful review by the AOC, it was determined that updating our approach was necessary to ensure alignment withcurrent industry practices and global trends. This update aims to streamline our approach in line with global bestpractices, moving towards a single, unified approach across all markets.

Russell Investments / Investment Stewardship Report/ 77

Referred Items
The Committee reviews those proposals that require more scrutiny and a non-prescriptive approach, and any proposals that are
not specifically addressed in our guidelines. At Russell Investments, we believe good stewardship requires careful considerationof each proposal on its individual merits. To this end, the Committee evaluates each proposal, considering the following factors:


Research conducted by our internal proxy analyst,

External research from our proxy administrator,

External research from Sustainalytics,



Input from our sub-advisers on voting and engagement, and

Input from the Active Ownership Team when a Russell Investments-led engagement has been previously conducted.

During 2023, 699 proposals were referred to Russell Investments’ internal proxy analysts, either because our Guidelines dictatedcase-by-case review or because the proposal topic was not covered by the Guidelines. Of the referred proposals, 62% were
evaluated and voted on by the Committee. The remainder of the referred proposals were of a technical nature, so our internal
proxy analysts were able to make a vote decision based on careful application of existing proxy voting guidelines without
additional input from the Committee. An overview of how the Committee has voted is provided on the graph below:

Exhibit 33: Russell Investments votes on referred items

Environmental
proposals*

23%

Socialproposals

77%

30%

70%

Governanceproposals

86%

AgainstAgainstManagement
Management

14%

With
With management
Management*includes “say on climate” proposals.
Source: Russell Investments, data as of December 31, 2023.
The Active Ownership Committee had the highest rate of support for governance-related proposals. Russell Investmentsemphasizes the importance of shareholder rights, which is reflected in our voting support of proposals which request:Right to Act by Written ConsentIndependent Board Chairman/Separation of Chair and CEOElimination of Supermajority Provisions

Voting across asset classes
The right to exercise our votes through non-equity asset classes varies by the type of asset and even among individual
investments. In all circumstances, we seek to achieve mutually beneficial outcomes while being consistent with our fiduciary
duty of protecting our clients’ interests. In cases where we can exercise our voting rights on environmental, corporate
governance, and social matters, we ensure that the same process and policies are applied across geographies and instruments.
For fixed income assets, the number of occasions when Russell Investments will be engaged in proxy voting will be very
limited. In 2023, the bondholder votes that Russell Investments cast were all of a technical nature.



As mentioned in the engagement section, we actively participate in voting items for private markets. Details and casestudies can be found in section 5.

Russell Investments / Investment Stewardship Report/ 78

Stock lending
As a fiduciary, Russell Investments maintains the voting rights for all holdings. We do not delegate voting to any of our subadvisers, though we may reach out to a sub-adviser for additional information regarding specific proxy votes. Our proxyadministrator, Glass Lewis, is responsible for managing the proxy ballots that Russell Investments receives based on ourholdings, a process that is monitored in turn by Russell Investments’ internal proxy coordinator using Glass Lewis’ online
Viewpoint platform. The proxy coordinator is responsible for ensuring all of Russell Investments’ voting rights are exercised andconducts a quarterly review of accounts with voting rights against the accounts on record with Glass Lewis.
Our policy on securities lending, as it applies to proxy voting, ensures that we exercise voting rights on behalf of our clients.
Glass Lewis currently produces a weekly report of shares with upcoming proxy votes that meet pre-determined criteria forpotential restriction and/or recall. Russell Investments’ policy requires a restrict/recall action for issuers that are either (1)undergoing M&A activity, or (2) issuers for which Russell Investments holds >2% of overall shares outstanding. Additionally, theActive Ownership Committee has discretion to restrict securities on a case-by-case basis. We restrict these securities (either 15
business days out from the record date, or as soon as we are notified, whichever comes first) from being loaned before theirrecord date, recalling any loans as necessary. The restriction is lifted one business day after the record date.

Proxy voting activity in 2023
Proxy voting is a fundamental tool for listed equity, whereby shareholders are entitled to express support or concern withaspects of corporate governance, operations, or disclosures. As stewards of our clients’ capital, we have an obligation to voteresponsibly and hold companies to account on their behalf.
Russell Investments’ proxy voting records are publicly available on our website here. We do not publish vote rationales beyond
those described in our custom Proxy Voting Guidelines.

Exhibit 33: Russell Investments votes on referred items

12,588

9,747

98,267

1,344

3,791

Meetings voted

Proposals voted

Shareholder proposals

Votes against provider

Votes against
management

97%

95%

1%

4%

13%

Of eligible meetings

Of eligible proposals

Of total voting activity

Of proposals voted

Of proposals voted

Source: Russell Investments, data as of December 31, 2023.

Russell Investments / Investment Stewardship Report/ 79

Exhibit 35: Voting activity per topic

1% 4%

1%
Audit/Financials

13%

Board Related

16%

Capital Management

5%

Changes to Company Statutes

7%

Compensation
M&A
Meeting Administration

53%

Shareholder Proposals

Source: Russell Investments, data as of December 31, 2023.

Proxy season overview
In 2023, Russell Investments voted on 98,267 individual proposals, representing 95% of proposals eligible, and on 9,747
individual meetings, representing 97% of meetings where Russell Investments was eligible to vote. As is usually the case, themajority of items voted relate to governance issues, with the largest portion being board related. The small percentage ofunvoted meetings were due to share blocking power of attorney markets (POAs) or operational barriers. Additionally, Russell
Investments did not cast any proxy votes for Russian issuers that were subject to sanctions by any jurisdiction from March 3,2022 onwards. Our proxy administrator suspended their engagement and research with these companies following the Russian
invasion of Ukraine, and as a result, we were unable to cast informed voting decisions and reached a decision to suspend voting
action for these entities.

Exhibit 36: Votes by issue

Audit/Financials

5%

95%

Board Related

14%

86%

Capital Management

15%

85%

Changes to Company Statutes

10%

Compensation
M&A
Management ESG proposals
Meeting Administration

90%

19%

81%

5%

95%

13%

87%

6%

94%

Shareholder Proposals- Environment- Social- Governance

23%

77%

28%

72%
44%

56%

Against Management

With Management

Source: Russell Investments, data as of December 31, 2023.

Russell Investments / Investment Stewardship Report/ 80

Russell Investments voted against management on 13% of proxy items and voted against Glass Lewis recommendations on 4%of proposals. 23% of votes against management were also against Glass Lewis’ recommendation, which is reflective of the
independence of Russell Investments’ guidelines and voting activity.
Russell Investments’ votes against management declined by approximately two percent year-over-year, however the largest
portion of these votes - 57% of votes against management - remained against the election of director candidates. Insufficient
independence was the most frequently cited reason for voting against a given director, coming up in about half of our votes
against director candidates. Over-boarding (Russell Investments will generally withhold support from candidates who serve on
the boards of five or more public companies) and inadequate gender diversity at the board level were the next most common
reasons for voting against. We also frequently disagreed with management proposals concerning compensation, voting against
approximately 18% of these proposals.

Exhibit 37: Russell Investments voting behavior

Audit/Financials

95%

5%

Board Related

87%

1% 12%

Capital Management

84%

16%

Company Statutes

93%

Compensation

7%

79%

M&A

21%
95%

Management ESG Propsals

5%

87%

13%

Shareholder Proposals- Environment- Social- Governance

22%

1%

26%

77%
1%

41%

72%
1%

58%
For

Abstain

AgainstSource: Russell Investments, data as of December 31, 2023.

Russell Investments / Investment Stewardship Report/ 81Proxy voting by region
Russell Investments applies a consistent proxy voting practice around the globe. We have exercised our votes across 86 different
countries during 2023. The distribution of our votes has shifted slightly: for the first time less than half of the proposals voted on
applied to companies based in Europe and North America while Asia-based companies (including Japan) accounting for nearly
40% of the votes. Oceania had the lowest voting activity registered.

Exhibit 38: Proxy voting distribution by region

25%

Canada &United States

20%

30%

EuropeAsia ex-Japan

9%
Japan

11%

Latin America &Caribbean

4%

Africa & Middle East2%

Oceania

Source: Russell Investments, data as of December 31, 2023.

Russell Investments / Investment Stewardship Report/ 82

Climate risk-related proposals
During 2023, our voting activity has reflected our view of climate risk as financial risk. In this regard, Russell Investments has
voted on 165 climate-change related proposals, including a meaningful portion that were “say on climate” and other climaterelated management proposals. We voted with management on 71% of these proposals. Only three shareholder proposals
passed, including one which requested increased emissions disclosure at a major energy company – this was approved overmanagement’s objection. The two other climate-change related shareholder proposals that passed, one at another energy
company and the other in the banking sector, had the support of management.

Exhibit 39: Votes on climate-related shareholder proposals

1%28%
Against Management
With Management
No rec from management71%

In line with our engagement focus areas, we have refreshed our voting guidelines regarding “say on climate” proposals. During
the 2023 season, Russell Investments voted against the climate transition reports at three companies, out of 26 suchmanagement proposals brought forward for an advisory vote, and supported climate transition plans at 23 additional companies.
Nineteen of the say on climate proposals were on the ballot at European companies, with the rest spread between Canada,
Australia, and South Africa.

Exhibit 40: Russell Investments votes on “say on climate” proposals

12%

Against Management
With Management

88%

Russell Investments / Investment Stewardship Report/ 83

Case study – Management Say-on-Climate proposal vs. shareholder
proposal requesting transition targets at major energy company
Country of Incorporation
Market Cap
SectorUnited Kingdom$210.2bn
EnergyManagement and shareholders alike have recognized the need for climate change strategy, but tensions can arise between
corporate strategies for transition and the goals that some shareholders believe should be set to manage long-term risk fromclimate change and GHG emissions. In some cases, management and shareholder proposal often competing visions. Russell
Investments evaluates every climate and transition-related proposal individually, based on the merits of the proposal, with
our fiduciary duty to our clients to deliver long-term benefits as the ultimate driver of all voting decisions.
Proposal Type: Management proposal on Energy Transition
Management recommendation
Russell Investments Vote

For
AgainstThis vote was unusual as it requested shareholders to provide a yes/no on the progress made towards the company’s statedclimate strategy. While the company had made progress towards its stated climate goals in the past year, the Active
Ownership Committee had significant cause for concern regarding the company’s overall strategy and thus the progress.
The company should enhance its current disclosures to address some unacknowledged risks and provide transparency
around the company’s CAPEX alignment with its stated transition goals.
Proposal Type: Shareholder proposal requesting Scope 3 emissions targets and alignment with the Paris Agreement
Management recommendation
Russell Investments Vote

AgainstAgainstThis resolution was binding in nature. Binding resolutions raise concerns because they limit the flexibility of the board toadapt to changing circumstances and make strategic decisions in the best interest of the company. Additionally, they canundermine the accountability of the board to shareholders, as it may feel constrained in its ability to exercise independentjudgment.

OutcomeRussell Investments’ Active Ownership Committee voted against both the management proposal and the shareholder
proposal concerning transition strategy. While the management proposal requested that shareholders provide assent to theprogress made towards its stated climate strategy, Russell Investments retains meaningful concerns about the overall
strategy despite management’s forward progress, prompting the AOC to vote against management’s proposal.
Conversely, while the Committee understood and generally supported the onus of the shareholder proposal in theory, we
could not support a binding vote on this matter. Supplanting the judgment of the board in this case would have been
inappropriate as it could, going forward, restrict management’s ability to develop strategies to address the transition to a
low-carbon economy in ways that would benefit shareholders.

Russell Investments / Investment Stewardship Report/ 84Voting on social issues
Our voting activity on social topics, including human capital management and human rights concerns, reflects an industry trend– as the total number of social shareholder proposals continues to increase on an annual basis, they are receiving less support
overall. In our opinion, the proportion of proposals put forward by shareholders which have evidentiary basis for support has
fallen. Not all shareholder proposals are created equal, which makes Russell Investments’ case-by-case approach more
important than ever. Russell Investments has opposed more than half of all socially-oriented shareholder proposals in 2023, withthe most frequently supported proposals pertaining to requests for increased disclosure at companies with public human capital
controversies, while rejecting proposals that were redundant, overly prescriptive, or, as in the case of “anti-ESG proposals,”
constructed in bad faith.
As part of our focus on human capital management, we will exercise our vote with companies that we identify as laggards, either
by supporting a relevant shareholder proposal or holding directors accountable by voting against their election at theshareholder meeting.
At Russell Investments, when assessing human capital related shareholder proposals, we consider taking voting action under thefollowing conditions:

Current practices and/or disclosures are deemed to be inadequate.

The proposal addresses a peer relative deficiency.

The proposal does not duplicate existing practices.



The board failed to provide commitment to address the proponent’s concerns.



The topic is relevant to the company and sector in which it operates.

If the proposal is overly prescriptive in detailing strategy/operational decisions, we may vote against.

Exhibit 41: Vote on human capital-related proposals

Political Spendingor Lobbying

56%

44%

Human Rights

65%

35%

Racial Equity Audit/Report

62%

38%

Human CapitalManagement

55%

Labour Practices
and Disclosures

45%
100%

AgainstFor

Source: Russell Investments, data as of December 31, 2023.

Russell Investments / Investment Stewardship Report/ 85

Case study – Voting on human-capital and reputational risks relating to labor controversy
Country of Incorporation
Market Cap
SectorManagement recommendation
Russell Investments Vote

United States$103.8bn
Consumer Discretionary
AgainstFor

Following significant media scrutiny regarding allegations of illegal anti-union practices attributed to company management,
shareholders took proactive steps to address concerns regarding employees' rights to freedom of association. In response,
they filed a proposal calling for an independent audit and comprehensive report to assess the company's adherence to laborlaws and its respect for employees' rights to form or join trade unions.

OutcomeAs a social issue, this proposal was referred to the Active Ownership Committee for further review, per our guidelines. The
Committee voted to support this proposal, alongside over 51% of shareholders. High-profile controversies can, at aminimum, result in reputational harm and less engaged employees. They can also lead to costly fines, litigation, or employee
actions, such as walkouts, that can cause significant disruption to the company's operations.

Holding the board accountable through voting
Good governance is the starting point for sound management. Russell Investments’ Proxy Voting Guidelines support governancestructures that ensure management and board members maintain independence, objectivity, and act in the best interest ofshareholders. We also emphasize the importance of shareholder rights.
As active ownership and engagement continue to be crucial tools for responsible investing, it is paramount that boards areprepared to collect and respond to shareholder feedback, particularly when a company receives significant dissent at their AGM.
Best governance practices will include a formal process for the board to engage with shareholders, and where this is not inplace, a company is likely to face increasing shareholder discontent. Engagement is an opportunity for a company to bridge any
gaps in understanding – companies which do not have an effective mechanism for shareholder engagement are likely to see
increased opposition to management proposals.

Case study – Voting against Say-on-Pay following an unsuccessful engagement
Country of Incorporation
Market Cap
SectorManagement recommendation
Russell Investments Vote

United States$49.4bn
Retail REITs
For
AgainstRussell Investments’ Active Ownership Team conducted an engagement with a self-administered and self-managed realestate investment trust (REIT) based in the U.S. prior to the company’s 2023 AGM, where we anticipated voting against
management on two items, as per our Guidelines. The purpose of the engagement was to gain a deeper understanding of thereasoning behind a significant discretionary grant and to express our concerns regarding the overall structure of theircompensation package.
During our discussion with the chair of the compensation committee, we discovered that they were unable to provide acompelling rationale for granting an all-cash one-off award to the company executive team without any performance
conditions attached. Moreover, we expressed significant concerns regarding the level of discretion allowed in thecompensation structure, yet the chair of the compensation committee did not acknowledge why the company’scompensation practices raised concerns.

Outcome
Our discussion with the chair of the compensation committee failed to provide clarity regarding the committee’s rationale orapproach to compensation structure. Consequently, we voted against the compensation package in accordance with our
Guidelines. The level of shareholder dissent following the 2023 AGM was practically unprecedented, with over 88% ofshareholders rejecting the company’s say-on-pay proposal.

Russell Investments / Investment Stewardship Report/ 86

6. Policies, processes, and procedures
supporting responsible investing

6.1 Our integrated approach to stewardship and investment


UK Stewardship Code – Principles 3
Japan Principles for Responsible Institutional Investors - Principle 2
The New Zealand Stewardship Code – Principle 6

At Russell Investments, we maintain a governance framework that is designed to ensure a coordinated and consistent approachto the management of conflicts of interests across all regions in which we operate. Our culture, supported by the Global Code of
Conduct, recognizes the fiduciary duties that we owe to our clients, and promotes the ethos of ensuring client interests are put
ahead of both the firm’s interests and the personal interests of its associates. As a fiduciary, we are expected to eliminate or
mitigate conflicts of interests and to make full disclosure of all material conflicts to our clients.
The Russell Investments Global Conflicts of Interest Policy provides guidance in identifying and handling actual and potential
conflicts of interest in the operation of its business, and each region has a supplemental conflict of interest policy to meet
specific jurisdictional requirements. Together, our global and local policies are in place to manage all potential or actual conflictsof interest in the best interests of our clients. Associates are required to comply with the Global Policy but also the requirementsof any applicable local conflict of interest policy in their jurisdiction.
Our Global Conflicts of Interest Policy is the responsibility of the Global Chief Compliance Officer who administers it with theoversight of Russell Investments’ Global Risk Management Committee. It is reviewed regularly with the latest review dated
February 2024.

Management of conflicts
Russell Investments maintains a governance framework to ensure a coordinated and consistent approach to management ofconflicts across all regions in which it operates.
The Russell Investments Global Conflicts of Interest Policy applies to all associates anywhere in the world, in connection withany activity related to Russell Investments or its business. Each associate is expected to avoid conflicts of interest where
possible, and to play their part in identifying any conflicts of interest, enabling Russell Investments to take appropriate action toeliminate or mitigate the conflict and/or make appropriate disclosures to our clients.
The controls which Russell Investments has in place to manage each potential or actual conflict of interest include effective
governance and stewardship; the segregation of duties; the creation of policies and procedures of information barriers;
remuneration policies that remove direct conflicts of interest; or setting pre-determined individual approval limits, over whichescalation and approval is required.

Russell Investments / Investment Stewardship Report/ 87

A number of global and regional committees have been established which play a key role in helping to ensure that the
management of conflicts is embedded in business processes. Specifically, from a global perspective:

The Global Risk Management Committee has been established to oversee Russell Investments’ risk management framework
including investment, credit and operational risk and it administers the Global Conflicts of Interest Policy.

Affiliated Business Oversight Committee – oversees selection of affiliated entities for investment advisory, brokerage andother related services.



Global Trade Management Oversight Committee – oversees and analyses trading arrangements and trade execution.

At a regional level, we have implemented local conflicts of interest policies and practices which are applicable to therequirements of the local jurisdiction and business, with oversight at a local level provided by the applicable management andgovernance bodies.
Where the organizational and administrative controls are deemed insufficient to effectively manage or prevent a potential or
actual conflict of interest, or to ensure effective stewardship, the matter is escalated in accordance with the regional policies andprocedures.
For example, for our EMEA businesses, a Conflicts of Interest Working Group has been established to assist in the managementof potential conflicts with its membership comprised of associates from business line management and support functions such as
Legal, Compliance, Risk and Operations. The working group considers and discusses all potential and actual conflicts of interest
arising in relation to Russell Investments’ business activities, whilst assessing the effective business management of thoseconflicts of interest. If it is not possible to manage a conflict of interest to a level of confidence that the risk of damage to aclient’s interests will be prevented, the Conflicts of Interest Working Group will identify the client disclosures that willsubsequently be necessary. The Board of each EMEA Group Company is responsible for overseeing the implementation ofarrangements to ensure effective stewardship and management of conflicts of interests, including review of the EMEA conflictsof interest policy. All situations identified as constituting a conflict of interest, or that may potentially give rise to a conflict ofinterest, are documented in the relevant conflict of interest maps, which detail the organizational and administrative controls inplace to manage them.

Russell Investments / Investment Stewardship Report/ 88Some common conflicts and controls which apply to Russell Investments Group are set out in the examples below:

Exhibit 41: Examples of conflicts and control procedures
CONFLICTCONTROL PROCEDURESThe Global Code of Conduct requires each of the regions to develop policies,
Employees might be able to benefit from awareness of confidential trading activity
standards and limitations regarding the personal trading activity of its
undertaken by Russell Investments (e.g., personal account dealing in a security that
forms part of a transition event or is traded by the direct investing team (dealing ahead/ associates to minimize the potential conflicts of interest relating to personalaccount dealing. Through regional policies, each associate is required to trade
front-running).
in their personal investment accounts lawfully and in a manner which avoids
actual or potential conflicts between the interests of the associate and theinterests of Russell Investments in our clients. This includes an obligation toreport certain accounts, holdings and transactions to regional compliance. In
particular, associates are prohibited from trading, either personally or on behalfof others, on material, non-public information or communicating suchinformation in violation of applicable law. They are also prohibited frompurchasing or selling ahead of client orders.
Any suspected instances of market abuse must be reported immediately to theregional Compliance team for investigation.
Employees could be induced to enter into contracts with third parties, to the detriment Associates are strictly prohibited from offering, paying or accepting
remuneration or consideration for the purpose of improperly influencing theof a segregated or fiduciary management client, or funds (where Russell Investments
actions of government officials, political parties, candidates for public offices or
acts as an Adviser/ Investment Manager or distributor).
others. They are also required to exercise particular care when extending
Employees might induce a client, distributor, money manager, or other service provider common business courtesies to public officials. Regional offices have specificinto doing business with Russell Investments where this is not in the best interest ofpractices relating to anti-bribery and corruption in alignment with local
other clients or funds.
regulatory and statutory standards, but there is a global requirement for
associates to promptly report any bribery or corruption concerns to theirregional compliance department or legal department.
Poor product design could adversely affect end clients; or lead to problems with market Russell Investments operates comprehensive procedures relating to productintegrity by enabling the firm to mitigate and/or dispose of its own risks or exposure to governance. The Global Product Governance Committee is the top-level
the underlying assets of the product where the firm already holds the underlying assets governing body for all product approvals and amendments, and it delegatessome authority to local product committees on a regional basis. As part of theon own account.
product governance process, the relevant product committee will consider
potential conflicts for this specific issue, with all potential issues assessed aspart of the product development and management processes.
For both new and existing products, consideration is given to whether the
product design or amendment / development introduces any new risks tocustomer best interests which may need to be mitigated or disclosed.
Russell Investments segregated, fiduciary management or other large clients investingin Russell Investments’ funds (‘target funds’) may result in significant influence on theinvestment strategy of the target fund (i.e., so that the strategy is more aligned to theinvesting client(s) or in the case of proposed significant redemptions, making a change
to the investment strategy to keep clients within the target fund).

The investment strategies of Russell Investments funds are overseen by theasset class sub-committees and the ISC. Additionally, the relevant regional
governing body will review the investment strategy as applicable.

Financial incentivization/reward of portfolio managers may lead to inappropriate
investment risks being taken (relative to the investment objective and policies) toprotect employee compensation.

Russell Investments has a Global Remuneration Policy that considers market
intelligence on compensation to be an important data point in the determinationof both overall and individual pay levels for all Russell Investments employees,
including senior executives and associates in risk and control positions.

The Russell Investments portfolio manager provides written details of theinvestment strategy proposal to the ISC to ensure, amongst other things, the fairtreatment of all investors. All proposals regarding initial investments required
approval of the ISC.

A Global Compensation Council reviews and approves compensation
opportunities for individuals based on their job responsibilities and market
levels of pay for organizations of appropriate size, business segments,
geography, complexity and profitability relative to Russell Investments.
In addition to market levels of compensation, quantitative and qualitative
assessments of Russell Investments’ performance and individuals’ contributions
to that performance, including Russell Investments risk management, whereapplicable, are important determinants of incentive compensation outcomes.
A global Sales Compensation Council (SCC) has been established to review andapprove sales commission plans. The SCC comprises members of the global
senior management team.
In order to align incentives with clients, portfolio managers are compensatedbased on the performance of the portfolios managed, as well as on Russell
Investments’ profits.

At Russell Investments, in regard to stewardship, we have specific conflicts of interest controls in respect of activities
surrounding employee outside interests, our active ownership and our investment management practices. The following outlines
the procedures for these areas:

Russell Investments / Investment Stewardship Report/ 89Outside interests
Outside business interests or directorships can create conflicts of interest with an associate’s obligations to Russell Investments,
which could have an adverse effect on the ability to meet our obligations to our clients and our funds (where we act as adviser,investment manager, distributor or otherwise).
All outside business interests or directorships of associates must be formally declared in accordance with the Russell
Investments Global Code of Conduct. Associates must obtain prior approval from their supervisor and their regional compliancedepartment for any outside business affiliation, employment, or acceptance of compensation from any other person or entity
including (but not limited to), the acceptance of directorships, governorships, or trusteeships, becoming an officer, director or
partner or any business organization, or receiving compensation from another organization. Detailed guidance is embedded in
the Global Code of Conduct, for consideration in terms of how to approach outside business activities in respect of both
employees and independent contractors of the organization.
All new associates must certify that they have read and understand the requirements in the Russell Investments Global Code of
Conduct, which includes requirements in respect of outside business interests. Associates must complete an annual declaration
to certify they have read, understand and continue to comply with the Global Code of Conduct.

Active ownership
The Russell Investments’ Conflicts of Interest Policy does not specifically reference stewardship. However, the implementation ofvarious processes to manage any potential conflicts of interest ensures that clients’ interests are at the forefront in relation to
stewardship. Our stewardship activities in relation to active ownership relate to proxy voting and corporate engagement, and wehave processes to manage potential conflicts in both these areas:
1. Proxy voting conflict of interest procedures.
Where Russell Investments maintains the voting rights for underlying securities, it appoints a proxy administrator that acts
within the guidelines set out in Russell Investments Proxy Voting Policy. Our proxy voting policies and procedures are designed
to ensure that those proxy voting decisions; (i) are made in accordance with the best interests of clients; and (ii) enable theActive Ownership Committee to resolve any material conflicts of interest relating to voting and engagement. Further details on
our Active Ownership Governance Structure can be found in the Governance of Stewardship section above.
Proxy Voting Guidelines are constructed to be aligned with international good practices and standards, and are applied to all
votable proxy items, without exception, for issuers that currently have, or recently had, an existing relationship with Russell
Investments, as either a client or vendor. Any votes that are not covered by the Guidelines, or any votes which require case-bycase review, are referred to the Active Ownership Committee for a review and vote. This process is further explained here.
For any votes referred to the Active Ownership Committee, potential conflicts of interest are mitigated by (i) the committee
structure itself, which requires a quorum for a final vote, and (ii) all votes submitted by committee members requiring acertification attesting that the voting member has no knowledge of any potential conflicts of interest between the client, Russell
Investments and its affiliates, as well as no personal material conflicts (such as personal stock ownership).
2. Corporate engagement conflict of interest procedures.
Structural separation – Russell Investments maintains a segregated reporting structure between active ownership and client
facing employees. Consistent with this, only ID associates engage with and provide feedback to companies.
Transparent and consistent selection process – Russell Investments uses the same process to identify engagement targets acrossthe board, without regard to any relationship with such parties.
Robust governance structure – The Active Ownership Team is required to seek approval from the firm’s Investment Strategy
Committee for all engagement targets identified, before taking any action (even in the case of those of a collaborative nature) to(i) ensure decisions are made in accordance with the best interests of clients; and (ii) enable the Active Ownership Committee toresolve any material conflicts of interest relating to voting and engagement.

Russell Investments / Investment Stewardship Report/ 90

2023 Investment management
In most circumstances, Russell Investments acts as a manager of managers rather than investing directly in securities. We haveidentified the following potential conflicts in respect of this model and, as a result, have implemented appropriate controls to
help mitigate these potential conflicts:

Exhibit 41: Examples of conflicts and control procedures
CONFLICTCONTROL PROCEDURES

The inappropriate selection or retention of managers for commercial reasons. For
example, appointing a money manager in return for AUM investment.

Our procedures for appointment retention and termination of managers follows
a quantifiable process based on the ability of the money manager’s product tocontribute meaningfully towards the fund’s/client’s overall risk and returnobjective and is overseen by the entity-level and global committees.

Unfairly allocating high-ranked managers across certain clients or fund complexes,
using up their spare capacity and inappropriately disadvantaging another client orfund complex.

The segregation of duties between the research analysts responsible formanager rankings and recommendations, and the go-to-market sales team, who
might have commercial rather than investment reasons for selecting a manager.

Recommending frequent money manager changes to a client in order to increase
revenue for Russell Investments.

Research Analysts receive no incentives to favor one manager over another.
Such analysts are therefore not directly influenced by AUM inflows, distributor
relationships, client relationships or commercial profit margins. Any changes
made or recommended are done so based on clear procedures for appointment,
as alluded to above.

Managers are required to manage their own conflicts of interest in accordance with the Russell Investments’ Conflicts of Interest
Policy, or with the manager’s own equivalent standard of policy. We monitor any material violations of these policies by the
managers.
As part of the firm’s ongoing due diligence process, managers’ control environments are evaluated for their ability to mitigate
conflicts of interest through ongoing employee training; use of monitoring processes and systems; their internal testing ofcontrols; and their governance process to address conflicts identified.

Outcomes to managing conflicts in practice
Below, we provide examples of how we have addressed actual or potential conflicts in 2023 in relation to stewardship.

Case study – Conflict of interest arising from use of affiliates for trading and execution
services
Russell Investments has an established trading desk that provides comprehensive brokerage services to both third-party
clients as well as certain affiliates. An inherent conflict exists because Russell Investments earns compensation for the
trading directed by its affiliates through its trading desk. Russell Investments manages this conflict of interest throughmonitoring of trade activity and periodic oversight by senior management.
We have established independent transaction cost analysis (TCA), where independent third parties provide Russell
Investments with benchmarking of the trading desk’s execution quality versus its peers. The independent TCA allows its
affiliates to continuously assess whether they receive best execution from the trading desk. In addition, Russell Investments
has established an internal committee, which oversees this relationship and receives reporting on execution quality. Theinternal committee meets on a quarterly basis and is comprised of members from Portfolio Management, Trading, Legal,
Compliance, Risk, and Operations.

OutcomeRussell Investments continues to use its trading desk as the primary executing broker for its affiliates. We recognize the risk
of future conflicts and have implemented monitoring (e.g., independent TCA) and governance to appropriately mitigate
these risks.

Russell Investments / Investment Stewardship Report/ 91

Case study – Information barriers to protect clients
The majority of Russell Investments’ equity interests are owned by certain private equity funds which form part of Russell
Investments’ ownership structure. In order to ensure any potential conflicts of interest that may arise from these ownerships
and circumstances are identified and properly managed, controls and measures have been put in place.
Russell Investments’ Compliance function regularly monitors for potential conflicts of interest in the portfolio holdings ofeach private equity fund in the ownership structure, with processes in place for protecting the independence and objectivityof our research where this eventuality might occur. This includes a specific requirement that all portfolio holdings in theprivate equity funds ownership structure that are determined by Russell Investments Compliance to be a controlling affiliateof that company, are blocked from user view on the Russell Investments Research and Advisory Systems – with thesesafeguards being compliance-monitored throughout the year.

OutcomeRelevant companies are blocked from the user view on the Russell Investments Research and Advisory Systems based on thiscontrol measure.

Case study – Individual conflict controls
The majority of Russell Investments’ equity interests are owned by certain private equity funds which form part of Russell
Investments’ ownership structure. Controls and measures have been put in place to ensure any potential conflicts of interest
that may arise from these circumstances are identified and properly managed.
Where conflicts of interest were to arise through a Russell Investments’ Senior Manager having a conflicting interest in, or
being appointed as a director of, an organization within the portfolio holdings of, or controlled by, our private equity
ownership structure, we have systems and controls in place to identify these circumstances and, where appropriate, will
manage conflicts arising from these ‘Control Affiliations’.

Outcome
Where control affiliations arise/exist, the Russell Investments Compliance function determines any potential portfolio holding
entity conflicts. The Compliance function examines a number of factors - including any trading relationships, business
relationships, finance relationships, direct financial interest, operational synergies or shared profit incentives between theportfolio holding organization and Russell Investments - to determine if any conflicts of interest exist and need managing.
We recognize the risk of future conflicts of interest occurring in connection with any such identified portfolio holdings, andtherefore subject them to ongoing, specific, and stringent safeguards.

Russell Investments / Investment Stewardship Report/ 926.2 Diversity and inclusion

UK Stewardship Code – Principle 2
Japan Principles for Responsible Institutional Investors - Principle 1
The New Zealand Stewardship Code - Principle 1

As a global company, we recognize the benefits of different sources of insight and knowledge. Valuing diversity gives us anadvantage by pooling ideas and providing solutions from more than one point of view. Effective management of diverse
perspectives enriches our culture and increases our ability to provide innovative solutions to our clients, while adding value toour shareholders and community.
Diversity is an integral part of our long-term growth strategy. Our ability to fulfil our purpose of improving financial security forpeople hinges on the quality of our workforce and our ability to provide appropriate solutions to a diverse group of clients. Our
approach to diversity and inclusion spans our internal corporate diversity efforts, as well as those of third-party service
providers. Details of our diversity efforts with regard to third party service providers are covered under section 4.3. Below, we
provide an overview of our internal corporate efforts on this subject.

Internal corporate diversity and inclusion efforts
At Russell Investments, we consider diversity through multiple lenses (e.g., gender, ethnicity, and sexual orientation). To
advance our efforts we have established a Corporate Social Responsibility (CSR) Council whose purpose is to increase diversity,
equity, and inclusion among employees, support workplace sustainability efforts, and promote community engagement throughvolunteering and giving. The CSR Council’s goals related to DEI include, but are not limited to, the following:Demonstrating leadership commitment and accountability for attracting, developing, and retaining diverse talentChampioning the advancement of diversity, equity, and inclusion, internally and in our communities



Fostering a culture of inclusion

Growing our diverse associate representation globally each year

Our stated purpose is to create an inclusive work environment that is free from discrimination and harassment, emphasizing ourcommitment to treating associates with respect. Equal opportunity extends to all employment aspects including hiring,promotions, transfers, terminations, training, working conditions, compensation, and benefits. Decisions pertaining toemployment must not be discriminatory, based on any characteristic protected by law. Further information can be found in our
CSR report.

Global Associate Resource Groups
These associate groups/committees (ARGs) are led by associates and are designed to increase engagement and understanding
while contributing to a more inclusive workplace. ARGs also facilitate dialogue and learning about inclusion issues acrossRussell Investments. These groups provide leadership and development opportunities for associates and support minorities
and/or women in the workplace.


Women's Associate Resource GroupBlack Associate Resource GroupLGBT & Allies (LGBTA) Associate Resource Group

Veteran's Associate Resource GroupIn addition, we have a Global Community Engagement Council, a Global Wellness Associate Resource Group, a Global
Sustainability Work Practices Group, and regional Social Committees – all collaborating with our Diversity, Equity, and Inclusion
Associate Resource Groups under the CSR umbrella on programming and initiatives

Russell Investments / Investment Stewardship Report/ 932023 Activity
Through 2023 we have continued to stay connected and have furthered our Diversity and Inclusion efforts. Highlights fromeducational events hosted this year include the following:Girl Scouts Financial Education ProgramReal Talk About Racism and Discrimination TrainingWhat’s Your Superpower? Women’s Leadership Panel and Networking EventA Conversation with Angel Bonilla – Trans Identity

Veteran’s Day Event Fireside Chat with Captain Alan Schrader, USN, Retired

Women’s ARG sponsored Generations: A Conversation with Dr. Jean TwengeBlack ARG Networking Socials

In addition to the many events hosted by the ARG’s, the following programs are also in place:

Women in Sales Excellence (WISE): A program to provide mentorship and educational opportunities to women in sales.

Global diversity mentorship program: An opportunity for diverse talent to reverse mentor senior executives.



Training: All new hires are required to complete unconscious bias training. Russell Investments provides anti-harassment
and discrimination training to associates every two years and, in several regions, requires the training upon hire.

Pay equality and disclosure: Russell Investments conducts a full compensation review each year, ensuring equal pay for
equal work with a focus on gender and race/ethnicity diversity. Russell investments voluntarily participates in the UK
Gender Pay Gap initiative, publishing results annually.



Policies and performance goals: Russell Investments ensures its global and regional policies are inclusive and free from
bias.



Global volunteering program whereby volunteer hours are matched and associates are afforded two days off for volunteer
activities of their choice per year.

Promoting diversity: The following incentives are in place globally to promote diversity:

Code of Ethics and Global Code of Conduct: Both Codes support overall ethical conduct and include statements on antiharassment and anti-discrimination that must be adhered to across the firm.



Global Citizen Goals: These goals are assigned to all associates (manager and individual contributor versions), and our EC
and year-end bonus compensation is dependent upon succeeding with these objectives.



Individual Contributor: Demonstrates good corporate citizenship by living Russell Investments’ values and principles andcontributing to our culture of compliance, meritocracy, inclusivity, and diversity.



Leadership: Serves as a role model for Russell Investments’ leadership behaviors, values, and principles. Demonstrates good
judgment with a focus on strengthening our culture of compliance, meritocracy, inclusivity, and diversity.

Further details of our efforts in this space can be found on our website.

Russell Investments / Investment Stewardship Report/ 946.3 Policy advocacy and collaborations


UK Stewardship Code – Principle 4, 10
Japan Principles for Responsible Institutional Investors - Principle 1
The New Zealand Stewardship Code - Principle 7

We actively collaborate in initiatives with industry participants, regulatory working groups and other stakeholders to collectively
deliver a well-functioning financial system. Over the course of 2023, we have contributed to the activities of the following
organizations:
Principles for Responsible Investment (PRI)
As a signatory to the PRI since 2009, Russell Investments has a long-standing relationshipwith the organization and has completed PRI assessments annually. Russell Investments
incorporates the PRI principles into our processes including through manager research,
portfolio management, and proxy voting and engagement. Furthermore, we purposefully
assess the initiatives and consultations driven by PRI, and we participate where relevant.

Institutional Investors Group on Climate Change (IIGCC)
We have been a member of IIGCC since 2015, actively collaborating and participating at
industry events and seminars. We also contribute to consultations as and when there is an
opportunity to do so.

Climate Action 100+
The role Russell Investments plays in this initiative is further explained under theengagement section here.

Nature Action 100
The role Russell Investments plays in this initiative is further explained under theengagement section here.

Transition Pathway Initiative (TPI)
We leverage the independent research and data from TPI to facilitate information sharing
and collective knowledge building. Moreover, we have completed the mapping of this open
source to set our own targets towards our net zero commitment.

Carbon Disclosure Project (CDP)
We use the global disclosure system provided by CDP as one of several sources that help
us to manage environmental impact in our portfolios. We have also collaborated with CDP
in engagement campaigns; for example, during 2022 we supported a campaign that targets
1,200 high impact companies on committing and setting a 1.5 degree-aligned, SBTiapproved science-based emissions reduction target.

Task Force on Climate-related Financial Disclosures (TCFD)
We have embedded the TCFD framework in our stewardship activities and regularly
engage with companies in this area. More details have been provided in the engagement
section of this report.

Russell Investments / Investment Stewardship Report/ 95

The Net Zero Asset Managers initiative
In 2021, Russell Investments joined the Net Zero Asset Managers Initiative. We havecommitted to work in partnership with interested clients on goals consistent with anambition to reach net zero emissions by 2050 or sooner across all its assets undermanagement. Further information can be found here.

Institutional Investing Diversity Cooperative (IIDC)IIDC members meet regularly to discuss key initiatives and specific action items that canencourage asset managers to offer more robust and comprehensive diversity data. We are
actively involved in IIDC through regular meetings, ad-hoc sub-committee projects, andindustry event speaking opportunities.

Investment Association (IA)Collaborations in 2023 include attending multiple industry seminars and responding to the
FCA proposed rules on sustainability.

Investors Against Slavery and Trafficking Asia Pacific (IAST APAC)
Russell Investments is a participating investor in the Investors Against Slavery andTrafficking Asia Pacific (IAST APAC) initiative is an investor-led, collaborative project. It
was established in 2020 to engage with companies in the Asia-Pacific region to promote
effective action in finding, fixing and preventing modern slavery in operations and supply
chains.

Investment Company Institute (ICI)
We support the organization to advocate on legislation, regulation and business policy,
affecting retail and institutional investors, equity and fixed income markets and related
products and services.

Securities Industry and Financial Markets Association (SIFMA)
Russell Investments supports SIFMA to advocate on legislation, regulation and business
policy that affects retail and institutional investors, equity and fixed income markets, andrelated products and services.

Responsible Investment Association Australasia (RIAA)
We actively contribute to the RIAA to ensure capital is aligned with achieving a healthysociety, environment and economy. Russell Investments has three of its Australian funds
certified by RIAA. RIAA’s Certification Symbol is recognized by investors and consumers
across the region, providing confidence that a product or provider is delivering on its
responsible investment promise and meeting the Australian and New Zealand standard for
responsible investing.

Department of Labor (DOL)
In the United States, we have joined industry trade associations and worked directly with
the Department of Labor to improve the language associated with how The Employee
Retirement Income Security Act of 1974 (ERISA) plan sponsors consider financiallymaterial factors related to ESG.

Russell Investments / Investment Stewardship Report/ 96

Case study – Collaborative consultations and advocacy
Throughout 2023, Russell Investments actively cooperated with various consultations organized by industry groups andregulators. These consultations comprised a range of activities, including participation in questionnaires, completion ofsurveys, and attendance at working group meetings. Through these channels, Russell Investments took the opportunity tocontribute our insights and expertise, thereby influencing the trajectory of collaborative programs and providing strategic
advice to shape the direction of industry bodies.

OutcomeCollaboration Group

Consultation

HM Treasury (HMT)

Future regulatory regime for Environmental, Social, and Governance (ESG) ratings providers

Investor Group

Letter from investors and corporates to call for Ofgem to be given a net zero mandate

PRI

Global Stewardship Resourcing Survey

CDP

SBT Engagement Campaign

FRC

UK Corporate Governance Code Consultation

IIGCC

Stewardship Alignment Questionnaire

DWP

Taskforce on Social Factors (TSF) consultation

Nature Action 100
TNFD

Feedback on Draft Benchmark Indicators
Capacity Building Survey

Thought Leadership
We provide a range of training and development opportunities for our client base to ensure that our clients are kept abreast of
key industry developments, as outlined previously in this report. During 2023, Russell Investments published 30 blog posts
relevant to ESG and responsible investing. These posts were written by investment professionals across various regions andteams, reflecting our broad range of services and diverse client base.

6.4 Reviewing policies and processes

UK Stewardship Code – Principle 5Japan Principles for Responsible Institutional Investors - Principle 1
The New Zealand Stewardship Code - Principle 2

Our policies cover all aspects of our investment and business practices, including our stewardship approach. Our Complianceand Legal teams continually review the regulatory landscape and add and refresh policies to ensure we are up to date withregulatory requirements. Furthermore, these reviews verify that our research aligns with best practice.
Our governance oversight combines formal and informal feedback loops. Metrics are generated on a range of ongoing practices;
these metrics are calculated regularly for items that are subject to ongoing review such as performance assessment, portfolio
risk exposures, compliance guideline reporting and productivity metrics.
In addition to regularly reviewed reports, ad hoc studies are conducted from time to time. These reports and studies encompass
a broader set of data over a range of time periods and are typically focused on a particular aspect of our investment process that
we are seeking to assess and improve.
Policy and process description documents are also regularly reviewed and updated. As an example, in 2023 we updated ourinternal Investment Philosophy and Process paper, which is a comprehensive reference guide on the beliefs and structure of ourinvestment process available to our investment and business teams. In this iteration, substantial updates and additions were
included for components of our investment process where recent enhancements have been made. These include in ESG-related
practices and active ownership, management of positioning strategies, implementation and governance structures.
When undertaking analysis, we aim to use the same underlying data and metrics that inform our investment decision making
and policy review process, as we use for client reporting and submissions to regulatory bodies. This alignment helps ensure that
our evaluation and reporting practices for both internal and external uses are fair and accurate.

Russell Investments / Investment Stewardship Report/ 97

Internal audit
In addition to continuous reviews and feedback loops, an independent Internal Audit (IA) team undertakes a rolling agenda ofreview on a range of key investment activities. The purpose of Russell Investments Group Internal Audit function is to provide
independent and objective assurance and consulting services designed to improve the organization’s controls and operations.
Internal Audit accomplishes this by providing risk-based and objective assurance, advice, and insight to enhance and protectorganizational value. Internal Audit helps the organization accomplish its objectives by bringing a systematic, disciplined
approach to test, evaluate and improve the effectiveness of governance, risk management and control processes.
The Russell Investments Group Internal Audit function utilizes a risk-based approach in developing the annual audit plan. The
audit universe of key processes is assessed to focus the audit plan on the areas of highest risk. Any issues identified by Internal
Audit require management action plans (MAPs) and are tracked to resolution by Internal Audit. The status of open issues isregularly reported to relevant boards and audit committees. Internal Audit validates resolution to close issues identified.
The IA process involves a structured assessment of key processes and risks, including detailed testing of mitigating controls
across the organization. These audits are designed to assess if systems and procedures are effective, efficient and function as
designed, thereby helping ensure:risks are appropriately identified and managed;

quality and continuous improvement are fostered in the organization’s control process;

significant financial, managerial, and operating information is prepared accurately and reliably; and

resources are adequately protected.

Case study – Internal responsible investing audit
During 2023, as part of our internal risk management processes, Russell Investments Risk Team conducted a comprehensive
review of all processes and procedures related to ESG-related practices, active ownership, and responsible investing. The
audit, which took place over several months, delivered improved efficiency and governance across all contributing business
units.

OutcomeThe outcome of the audit led Russell Investments to reinforce mechanisms which connect daily responsible investing work to
the Investment Strategy Committee to achieve stronger oversight. Russell Investments has three committees which now
provide regular, direct updates to the ISC on responsible investing matters – the Global Exclusions Committee, the Active
Ownership Committee, and the Investment Division Responsible Investing Committee.
In addition, Russell Investments decided to increase the frequency of updates to the firm’s Executive Committee (EC) fromannual to at least semi-annual. The Responsible Investing Council (RIC) Heads and/or their operating committee sponsors
provide updates on firmwide ESG and sustainable investing strategies and milestones including both internal KPIs and public
commitments, such as the United Nations-supported Principles for Responsible Investment (UNPRI), The UK StewardshipCode, and the Net Zero Asset Managers Initiative.

Russell Investments / Investment Stewardship Report/ 98

7. Appendix:
Stewardship code mappings

7.1 The UK Stewardship Code
PRINCIPLEREQUIREMENTS

PAGES

Principle 1

Signatories’ purpose, investment beliefs, strategy, and culture enable stewardship that creates long-term value for clients andbeneficiaries leading to sustainable benefits for the economy, the environment and society.

Signatories should explain the purpose of the organization and an outline of its culture, values, businessmodel and strategy

7, 8Signatories should explain their investment beliefs, i.e., what factors they consider important for desired
investment outcomes and why

8-10

Signatories should explain what actions they have taken to ensure their investment beliefs, strategy, andculture enable effective stewardship

4-6, 10Signatories should disclose how their purpose and investment beliefs have guided their stewardship,
investment strategy and decision-making

4-6, 10Signatories should disclose an assessment of how effective they have been in serving the best interestsof clients and beneficiaries.

10, 11, 17, 21-25

Principle 2

Signatories’ governance, resources and incentives support stewardship.

Signatories should explain how their governance structures and processes have enabled oversight andaccountability for effective stewardship within their organization and the rationale for their chosen
approach.

26- 32Signatories should explain how they have appropriately resourced stewardship activities, including theirchosen organizational and workforce structures

26- 32Signatories should explain how they have appropriately resourced stewardship activities, including theirseniority, experience, qualifications, training and diversity

31, 32, 93, 94

Russell Investments / Investment Stewardship Report/ 99Signatories should explain how they have appropriately resourced stewardship activities, including theirinvestment in systems, processes, research and analysis

32-38

Signatories should explain how they have appropriately resourced stewardship activities, including theextent to which service providers were used and the services they provided

31, 32, 45-51

Signatories should explain how any performance management or reward programs have incentivized
the workforce to integrate stewardship and investment decision-making

32

Signatories should disclose how effective their chosen governance structures and processes have beenin supporting stewardship; and Signatories should disclose how they may be improved

29, 30Principle 3

Signatories manage conflicts of interest to put the best interests of clients and beneficiaries first.

Signatories should disclose their conflicts policy and how this has been applied to stewardship

87-92

Signatories should explain how they have identified and managed any instances of actual or potential
conflicts related to stewardship.

87-92

Signatories should disclose examples of how they have addressed actual or potential conflicts

91, 92

Principle 4

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

Signatories should explain how they have identified and responded to market-wide and systemic risk(s),as appropriate.
Signatories should explain how they have worked with other stakeholders to promote continued
improvement of the functioning of financial markets.

42- 4418, 19, 95-97

Signatories should explain the role they played in any relevant industry initiatives in which they haveparticipated, the extent of their contribution and an assessment of their effectiveness, with examples.

95-97

Signatories should explain how they have aligned their investments accordingly.

42- 44Signatories should disclose an assessment of their effectiveness in identifying and responding tomarket-wide and systemic risks and promoting well-functioning financial markets.

42- 44

Principle 5Signatories review their policies, assure their processes and assess the effectiveness of their activities.

Signatories should explain how they have reviewed their policies to ensure they enable effective
stewardship

97-98

Signatories should explain what internal or external assurance they have received in relation to
stewardship (undertaken directly or on their behalf) and the rationale for their chosen approach98

Signatories should explain how they have ensured their stewardship reporting is fair, balanced andunderstandable

13-16, 21-25

Signatories should explain how their review and assurance has led to the continuous improvement ofstewardship policies and processes

98

Principle 6

Signatories take account of client and beneficiary needs and communicate the activities and outcomes of their stewardship andinvestment to them.

Signatories should disclose the approximate breakdown of their client base, for example, institutionalversus retail, and geographic distribution

11-13

Signatories should disclose the approximate breakdown of assets under management across asset
classes and geographies

11-13

Russell Investments / Investment Stewardship Report/ 100

Signatories should disclose the length of the investment time horizon they have considered appropriate
to deliver to the needs of clients and/or beneficiaries and why

11, 17Signatories should explain how they have sought and received clients' views and the reason for theirchosen approach

20-25

Signatories should explain how assets have been managed in alignment with clients' stewardship andinvestment policies

20-25

Signatories should explain what they have communicated to clients about their stewardship andinvestment activities and outcomes to meet their needs, including the type of information provided,
methods and frequency of communication to enable them to fulfil their stewardship reporting
requirements.

13-16

Signatories should explain how they have evaluated the effectiveness of their chosen methods tounderstand the needs of clients and/or beneficiaries

20-25

Signatories should explain how they have taken account of the views of clients and what actions they
have taken as a result.

20-25

Principle 7

Signatories systematically integrate stewardship and investment, including material environmental, social and governance issues andclimate change, to fulfil their responsibilities.

Signatories should disclose the issues they have prioritized for assessing investments, prior to holding,monitoring through holding and exiting. This should include ESG issues of importance to them.

33- 38Signatories should explain how integration of stewardship and investment has differed for funds, asset
classes and geographies

17-25

Signatories should explain how they have ensured tenders have included a requirement to integrate
stewardship and investment, including material ESG issues

17-25, 33- 38

Signatories should explain how they have ensured the design and award of mandates included
requirements to integrate stewardship and investment to align with the investment time horizons ofbeneficiaries

17-25, 33- 38

Signatories should explain the processes they have used to integrate stewardship and investment,
including material ESG issues, to align with the investment time horizons of clients and/or beneficiaries

17-25, 33- 38, 43, 44

Signatories should explain the processes they have used to ensure service providers have received clear
and actionable criteria to support integration of stewardship and investment, including material ESG
issues17-25, 33- 38, 43, 44

Signatories should explain how information gathered through stewardship has informed acquisition,
monitoring and exit decisions, either directly or on their behalf, and with reference to how they havebest served clients and/or beneficiaries

17-25, 33- 38, 43, 44

Principle 8

Signatories monitor and hold to account managers and/or service providers

Signatories should explain how they have monitored service providers to ensure services have beendelivered to meet their needs.

45- 50Signatories should explain how the services have been delivered to meet their needs

45- 50Signatories should explain the action they have taken where signatories' expectations of their managers
and/or service providers have not been met

45- 50Principle 9Signatories engage with issuers to maintain or enhance the value of assets

Signatories should explain how they have selected and prioritized engagement (for example, key issues
and/or size of holding)Russell Investments / Investment Stewardship Report

55-58

/ 101

Signatories should explain how they have developed well-informed and precise objectives forengagement with examples

55-60, 70-75

Signatories should explain what methods of engagement and the extent to which they have been used

52, 55, 66

Signatories should explain the reasons for their chosen approach, with reference to their disclosure
under Context for Principle 1 and 655-60

Signatories should explain how engagement has differed for certain funds, assets, or geographies

65-68

Signatories should describe the outcomes of engagement that is ongoing or has concluded in thepreceding 12 months, undertaken directly or by others on their behalf.

52-58, 67-75

Principle 10

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

Signatories should disclose what collaborative engagements they have participated in and why,
including those undertaken directly or by others on their behalf.
Signatories should describe the outcomes of collaborative engagement.
Principle 1153- 55, 95-97
53- 55Signatories, where necessary, escalate stewardship activities to influence issuers.

Signatories should explain how they have selected and prioritized issues, and developed well-informed
objectives for escalation

58- 60Signatories should explain when they have chosen to escalate their engagement, including the issue(s)and the reasons for their chosen approach, using examples

58- 60Signatories should explain how escalation has differed for funds, assets or geographies

58- 60Signatories should describe the outcomes of escalation either undertaken directly or by others on theirbehalf58- 60Principle 12

Signatories actively exercise their rights and responsibilities

Signatories should explain how they exercise their rights and responsibilities, and how their approachhas differed for funds, assets or geographies

76-80

For listed equity assets signatories should disclose their voting policy, including any house policies andthe extent to which funds set their own policies

76-80

For listed equity assets signatories should state the extent to which they use the default
recommendations of proxy advisers

78, 79For listed equity assets signatories should report the extent to which clients may override a house policy

76-80

For listed equity assets signatories should disclose their policy on allowing clients to direct voting insegregated and pooled accounts

76-80

For listed equity assets, signatories should state what approach they have taken to stock lending,recalling lent stock for voting and how they seek to mitigate 'empty voting'
For listed equity assets, signatories should disclose the proportion of shares that were voted in the past
year and why

79

76-80

For listed equity assets, signatories should provide a link to their voting records, including votes
withheld if applicable79

For listed equity assets, signatories should explain their rationale for some or all voting decisions

79-86

Russell Investments / Investment Stewardship Report/ 102For listed equity assets, signatories should explain how they have monitored what shares and voting
rights they have

79-86

For fixed income assets, signatories should explain their approach to seeking amendments to terms andconditions in indentures or contracts

79

For listed equity assets, signatories should provide examples of the outcomes of resolutions they havevoted on over the
past 12 months

79-86

Signatories should explain how they exercise their rights and responsibilities, and how their approachhas differed for funds, assets or geographies

79-86

7.2 Japan Principles for Responsible Institutional Investors
PRINCIPLEREQUIREMENTS

Principle 1

Institutional investors should have a clear policy on how they fulfil their stewardship
responsibilities and publicly disclose it.

Principle 2

Institutional investors should have a clear policy on how they manage conflicts of interestin fulfilling their stewardship responsibilities and publicly disclose it.

87- 92

Principle 3

Institutional investors should monitor investee companies so that they can appropriately
fulfil their stewardship responsibilities with an orientation toward the sustainable growthof the companies.

52-75

Principle 4

Institutional investors should seek to arrive at an understanding in common with investee
companies and work to solve problems through constructive engagement with investee
companies.

52-75

Principle 5

Institutional investors should have a clear policy on voting and disclosure of voting
activity. The policy on voting should not be comprised only of a mechanical checklist; itshould be designed to contribute to the sustainable growth of investee companies

Principle 6

Institutional investors in principle should report periodically on how they fulfil theirstewardship responsibilities, including their voting responsibilities, to their clients andbeneficiaries.

11-25, 79

Principle 7

To contribute positively to the sustainable growth of investee companies, institutional
investors should develop skills and resources needed to appropriately engage with thecompanies and to make proper judgments in fulfilling their stewardship activities basedon in-depth knowledge of the investee companies and their business environment andconsideration of sustainability consistent with their investment management strategies.

26-38

Principle 8

Service providers for institutional investors should endeavor to contribute to theenhancement of the functions of the entire investment chain by appropriately providing
services for institutional investors to fulfil their stewardship responsibilities.

45-51

Russell Investments / Investment Stewardship Report

PAGES

7-10, 39-41, 52-75, 93, 94,
95-98

76-79

/ 103

7.3 The New Zealand Stewardship Code
PRINCIPLEREQUIREMENTS

Principle 1

Signatories will establish, and publicly articulate, how their investment philosophy,
governance structures, and resourcing supports the goals of effective stewardship.

Principle 2

Signatories will develop and implement measurable and effective stewardshippolicies.

Principle 3

Signatories will incorporate material ESG matters into their investment decisions
and stewardship practices.

17-25, 33-44

Principle 4

Signatories will engage regularly and effectively with underlying managers,
issuers, and other key stakeholders

45-51, 52-75

Principle 5Signatories will exercise voting rights in accordance with their investment
mandate, and regularly and transparently disclose voting actions and outcomes.

76-76

Principle 6

Signatories will endeavor to avoid any conflict of interest that does not put the bestinterests of their clients and beneficiaries first and explain their approach to
managing any conflicts of interest that arise.

87- 92

Principle 7

Signatories will work collaboratively to amplify investor influence on ESG matterswith issuers, policy makers, index providers, standard setters, and other key
stakeholders.

48, 49, 50, 95- 97

Principle 8

Signatories will regularly measure, and publicly report, on their actions taken to
support stewardship, and demonstrate how these have contributed to the goals ofeffective stewardship.

11-25, 78, 79

Principle 9Signatories will invest to improve clients’ and beneficiaries’ awareness of
stewardship, improve their internal capabilities, and provide resources to deliver
impactful stewardship.

11-25

Russell Investments / Investment Stewardship Report

PAGES

7-10, 26-32, 93, 94
11- 25, 41, 52, 70, 76, 77, 79, 97,
98

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QUESTIONS?
Call Russell Investments Active Ownership orvisit russellinvestments.com/InvestResponsibly

ABOUT RUSSELL INVESTMENTS
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range of investment capabilities to institutional investors, financial intermediaries, andindividual investors around the world. Since 1936, Russell Investments has beenbuilding a legacy of continuous innovation to deliver exceptional value to clients,
working every day to improve people’s financial security. Headquartered in Seattle,
Washington, Russell Investments has offices worldwide, including Dubai, London, New
York, Paris, Shanghai, Sydney, Tokyo, and Toronto.

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