ESG INTEGRATION
PRINCIPLES ANDGUIDELINESESG Integration Principles and Guidelines – December 2022 - 2

FOREWORD
In a fast changing world, our focus is on achieving long-term sustainable returns for our clients. That is why wecommitted to integrating sustainable investing practices across our investment strategies. We believe this is in thefinancial interest of our clients, and supports the overall functioning of markets and the economy at large.
BNP Paribas Asset Management (BNPP AM) has been a major player in sustainable investment since 2002, when welaunched our first socially responsible investment (SRI) fund and set up a dedicated ESG (Environment, Social andGovernance) research team – the precursor of our Sustainability Centre. We were also a founding signatory of thePrinciples for Responsible Investment (PRI) in 2006. Since then, we have strived to implement all six principles evermore effectively and continued to develop our approach, regularly reporting on our achievements in terms of meeting
our PRI goals.
In 2019, we launched our first Global Sustainability Strategy (GSS), a firm-wide blueprint to mainstream and increase
BNPP AM’s sustainability ambition, including targets to align our investment portfolios and engagement activity with asustainable future.

Jane Ambachtsheer
Global Head ofSustainability

As part of the GSS, we define our pillars of sustainable investment – a critical component of which is ESG integration, i.e. having our analysts andportfolio managers incorporate relevant ESG factors into their company or asset evaluation and investment decision-making processes. Our GSS also
outlines our philosophy and sustainable investment beliefs. The process to integrate ESG is guided by these ESG integration principles andguidelines.
We believe that we should apply these principles and guidelines to all asset classes and regions, to the extent possible. We actively promote theseprinciples and guidelines to our existing delegated managers and managers we partner with.
Importantly, the 2022 update to our ESG Integration Principles and Guidelines comes at a dynamic time in sustainable finance. We have recently
launched our Net Zero Roadmap and evolved in line with the Sustainable Finance Disclosure Regulation (SFDR) disclosure regime. Both of theseefforts are actively evolving in response to changes in the real economy and Regulation.. We will continue to update these guidelines as our experienceand approach evolve.

ESG Integration Principles and Guidelines – December 2022 - 3CONTENTSForeword .......................................................................................................................................................................................................................... 2Contents ........................................................................................................................................................................................................................... 3Introduction ....................................................................................................................................................................................................................... 4
How does BNPP AM approach sustainable investing?................................................................................................................................................ 4
Our ESG Integration Principles and Guidelines ............................................................................................................................................................... 5A.

ESG Integration principles ................................................................................................................................................................................. 5

Philosophy.................................................................................................................................................................................................................... 5
Investment Process...................................................................................................................................................................................................... 5Research ...................................................................................................................................................................................................................... 5B.

ESG Integration guidelines ................................................................................................................................................................................ 5

ESG Research & KPIs ................................................................................................................................................................................................ 5Exclusions .................................................................................................................................................................................................................... 6
Stewardship and Engagement ..................................................................................................................................................................................... 6
C.

What is the scope of application of our approach to sustainable investing? ...................................................................................................... 7Disclaimer ......................................................................................................................................................................................................................... 8

ESG Integration Principles and Guidelines – December 2022 - 4

INTRODUCTION
HOW DOES BNPP AM APPROACH SUSTAINABLE INVESTING?
Our approach encompasses a number of elements, including:
1. ESG integration
2. Stewardship (proxy voting, engagement and public policy)
3. Responsible business conduct
4. Forward-looking perspective: the 3Es (Energy transition, Environmental sustainability, Equality & inclusive growth)
5. ‘Sustainable +’ solutions
6. “Walking the talk”: our own Corporate Social Responsibility (CSR) policy as a firm
Together, these approaches strengthen the way we invest, including how we generate investment ideas, construct portfolios, control for risk, and use
our influence with companies and markets. Further information on each of these components can be found in the GSS.
BNPP AM – A Six Pillar sustainable investing approach

Source: BNP Paribas Asset Management, December 2022

ESG Integration Principles and Guidelines – December 2022 - 5OUR ESG INTEGRATION PRINCIPLES AND GUIDELINESAt BNPP AM, we define common ESG Integration Principles and Guidelines to support and enhance the process by which analysts and portfoliomanagers can integrate a consideration of relevant ESG factors into their investment decision-making. For our wider investment philosophy andsustainable investment beliefs please refer to our Global Sustainability Strategy.

A. ESG INTEGRATION PRINCIPLESPHILOSOPHY
 Sustainability is embedded in our investment philosophies.
 We recognise that the level of ESG integration achievable over short to medium term horizons varies between asset classes and strategies.
 Some common principles for ESG integration will apply across all asset classes, while others are asset class, region or strategy-specific.

INVESTMENT PROCESS Each investment team is responsible for their investment process, and all investment research, analysis and decisions resulting from the applicationof this process.
 Investment teams are ultimately responsible for the integration of ESG factors in their investment processes, in line with the common ESG
Integration Principles and Guidelines.

RESEARCH
 ESG analysis on individual entities will concentrate on those factors deemed to be material for the respective sector by the Sustainability Centre,with input from the investment teams.
 Qualitative ESG analysis on individual entities will primarily be undertaken within the investment teams, in collaboration with the SustainabilityCentre.

B. ESG INTEGRATION GUIDELINES1
ESG RESEARCH & KPIS
 We will typically avoid investing in a public entity without ESG analysis, with a process for qualitative ESG analysis available to investors. We
maintain minimum coverage thresholds for funds (90% for developed markets and 75% for emerging markets, mid-small caps and high yield),
performing qualitative ESG analysis in the absence of a quantitative ESG rating when thresholds are in breach.
 We will avoid investing in a private entity without performing ESG due diligence (which could include qualitative analysis,or receiving a completedESG questionnaire).
 Integrating ESG factors into our investment processes should have a measurable positive impact on the ESG characteristics of portfolios. As aresult, we aim to hold portfolios with a more positive ESG scores and a lower carbon footprint than their respective (invested) benchmarks. Thisdata is included in monthly factsheets for in-scope funds.
Note: The above KPIs apply only to corporate and sovereign issuers; derivatives and cash are excluded at this stage.

1 Please refer to the scope of application of those guidelines in the below “Scope of our approach to sustainable investing”

ESG Integration Principles and Guidelines – December 2022 - 6

EXCLUSIONSAs outlined in our Responsible Business Conduct Policy (available on our website): We will not invest in companies in violation of the UN Global Compact Principles, the UN Guiding Principles on Business and Human Rights or theOECD Guidelines for Multinational Enterprises (OECD MNE Guidelines) via the process outlined in our Policy2.
 Companies struggling to meet the standards laid down in the UN Global Compact Principles, the UN Guiding Principles on Business and HumanRights or OECD MNE Guidelines may be put on a watch list (or not invested in).
 We will implement BNPP AM’s sector policies, in collaboration with the BNP Paribas Group for Group-level policies.

STEWARDSHIP AND ENGAGEMENT
 We will be “active owners” of our clients’ investments through our stewardship activities.
 We will avoid investing in a weakly rated entity3 (in active portfolios4) without documenting the risks and/or engaging or planning to actively engage
in the near future.
 Where weakly rated entities are non-responsive to engagement, we may use our voting rights to and oppose the following categories of resolutions
depending on the market: Financial Statements / Director and Auditor Reports; Discharge of Board and Management or Board Elections. Moredetails are available in our Governance and Voting Policy.

2 Given coverage constraints from our data providers, we may not be able to check all investable companies via a systematic process. In thoseinstances, we plan to be transparent on the scope of companies that have been checked.
3 We use decile 10 as a proxy for weakly rated entities (our ESG score range from zero to 99 with issuers ranked in deciles against peers, decile 10
being the lowest one). For more information, see: ESG Scoring Framework - BNPP AM Corporate English (bnpparibas-am.com).
4 Excluding mandates that do not follow the Responsible Business Conduct Policy and sovereign entities.

ESG Integration Principles and Guidelines – December 2022 - 7C. WHAT IS THE SCOPE OF APPLICATION OF OUR APPROACH TO SUSTAINABLE
INVESTING?
Our goal is to integrate the pillars of our sustainable investing approach across our investment strategies. The following table provides the detail ofwhat this means in practice, that is, which elements apply to which of parts of our investments.
Scope of our approach to sustainable investing
Open-ended funds(article 6 funds
domiciled inEurope)*

Open-ended funds(article 8/9 funds
domiciled in Europe)*

Mandates

Index funds,ETFs andSystematic approaches(art 8/9)

Index funds, ETFs andsystematic approaches(art 6)No

BNPP AM
ESG
Integration
Principles andGuidelines

NoYes

Can be customised by client

BNPP AM
Stewardshipand Proxy
VotingPolicies

Yes***

Yes***

Yes***

Integration of sustainability
practices is defined by the index
construction. The target is to alignit with BNPP AM approach when
feasible**

Yes***

No

Yes***

Customised
BNPP AM
Responsible
BusinessConduct
PolicyYes

Yes

Systematically proposed tonew clients but client opt-out
possible
Bespoke client ESG exclusions andpolicies may be implemented- Synthetic replication: the RBC
policy is applied to the assets heldby the funds- Physical replication: exclusions
are defined by the index
construction. The target is to alignthem with BNPP AM approach
when feasible

Mixed- Synthetic replication: the RBC
policy is applied to the assets heldby the funds- Physical replication: do not apply
the RBC policy*Excludes all local funds domiciled outside of Europe and joint ventures. For these local affiliated entities for which BNPP AM have operational control, we areworking to progressively integrate ESG considerations in the investment process. Where we use external managers for open-ended funds domiciled in Europe, aspart of its due diligence process, BNPP AM reviews the manager’s responsible investment policies, but these managers are not expected to apply the same
standards as the BNPP AM ESG Integration Principles and Guidelines.
**ETF and index strategies aim to replicate an index. The integration of sustainability practices is therefore typically defined by the index construction. Where theindices are solely constructed by third party index providers, BNPP AM only reviews the index construction methodology, including the integration of sustainability.
The following elements may be analysed, including, but not limited to: : source and quality of ESG data used, legitimacy and expertise of the ESG data and/or index
provider(s), ESG index methodology including ESG sector exclusions and integration of ESG criteria for securities selection and weightings, ESG rating of the index
versus the relevant investment universe, requirements of the relevant benchmark in terms of ESG disclosure, Paris Aligned Benchmark (PAB) or Climate Transition
Benchmark (CTB) classification. Where indices are customized by the index provider for BNPP AM, BNPP AM will aim to apply the components of our ESG
integration guidelines where this is feasible and by applying the index providers tools and data.
*** As per our Governance and Voting Policy, our voting rights are exercised on equities for mutual funds, UCITS, AIF, foreign investment funds, mandates and forEmployee Investment Funds for which voting rights are delegated to BNPP AM. Our voting scope is made up of companies for which aggregated positions meet oneof the three following conditions: represents 90% of our aggregated stock positions, represents 0.1% or more of the company’s market capitalization, ad hoc demandor local market regulations.

ESG Integration Principles and Guidelines – December 2022 - 8

DISCLAIMER
BNP Paribas Asset Management France, “the investment management company,” is a simplified joint stock company with its registered office at at 8, rue du Port
92000, Nanterre, France, RCS Paris 319 378 832, registered with the “Autorité des marchés financiers” under number GP 96002.
This material is issued and has been prepared by the investment management company.
This material is produced for information purposes only and does not constitute:
1. an offer to buy nor a solicitation to sell, nor shall it form the basis of or be relied upon in connection with any contract or commitment whatsoever or
2. investment advice.
This material makes reference to certain financial instruments authorised and regulated in their jurisdiction(s) of incorporation.
No action has been taken which would permit the public offering of the financial instrument(s) in any other jurisdiction, except as indicated in the most recent prospectus
and the Key Investor Information Document (KIID) of the relevant financial instrument(s) where such action would be required, in particular, in the United States, to US
persons (as such term is defined in Regulation S of the United States Securities Act of 1933). Prior to any subscription in a country in which such financial instrument(s)is/are registered, investors should verify any legal constraints or restrictions there may be in connection with the subscription, purchase, possession or sale of thefinancial instrument(s).
Investors considering subscribing to the financial instrument(s) should read carefully the most recent prospectus and Key Investor Information Document (KIID) andconsult the financial instrument(s’) most recent financial reports. These documents are available on the website.
Opinions included in this material constitute the judgement of the investment management company at the time specified and may be subject to change without notice.
The investment management company is not obliged to update or alter the information or opinions contained within this material. Investors should consult their own
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Given the economic and market risks, there can be no assurance that the financial instrument(s) will achieve its/their investment objectives. Returns may be affectedby, amongst other things, investment strategies or objectives of the financial instrument(s) and material market and economic conditions, including interest rates, market
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Past performance is not a guide to future performance and the value of the investments in financial instrument(s) may go down as well as up. Investors may not getback the amount they originally invested.
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