Environmental, Social and Governance Philosophy Statement

Fisher Investments believes ESG investors are best served by an investment process that considers both top-down and bottom-up factors. Integrating ESG analysis at the country, sector and stock levels consistent with clients’ investment goals and ESG policies maximises the likelihood of achieving desired performance and improving environmental and social conditions worldwide.

Fisher Investments (FI) considers environmental, social and governance (ESG) factors throughout the investment process. Additionally, FI regularly screens and tailors the investment approach for separately managed accounts depending on the particular guidelines mandated by the client.

• ESG factors are among the many drivers considered by FI’s Capital Markets Analysts and FI’s IPC when developing country, sector and thematic preferences. Environmental regulation, social policy, economic and market reforms, labour, and human rights are among ESG factors assessed when determining country and sector/ industry allocations and shaping an initial prospect list of portfolio positions.
• FI’s IPC, with the assistance of FI’s Securities and Capital Markets Analysts, determines the materiality of the ESG considerations based on the exposure among publically-traded companies in these categories. Higher materiality could imply larger ESG-related risks or opportunities, and may influence sector and country weight preferences as well as individual stock selection. The investment strategy and positioning reflects Fisher Investments’ outlook over a 12-18 month horizon.
• At a client’s discretion, FI is able to refine prospective equity lists further by applying the firm’s or client‑provided ESG screens to the list of prospective securities for separately managed accounts. Please reference the appendix for a sample of the firm’s screens employed for most ESG portfolios. FI’s screening process leverages MSCI ESG Research capabilities to identify and remove portfolio candidates involved in business activities deemed inconsistent with FI’s, or client-provided, screens.

FI’s Securities Analysts perform fundamental research on prospective investments to identify securities with strategic attributes consistent with the firm’s top-down views and competitive advantages relative to their defined peer group. The fundamental research process involves reviewing and evaluating a comprehensive set of qualitative and quantitative data, including ESG factors, prior to purchasing a security. Factors considered in portfolios include, but are not limited to: shareholder concentration, corporate stewardship, environmental opportunities & liabilities, and human or labour rights controversies. Generally, FI would choose not to invest in companies when, in its opinion, security level issues: (i) violate a client mandated ESG policy or (ii) present an inordinate risk to a company’s operational or financial performance or (iii) appear to present undue headline risk to share price performance.

Please see FI’s ESG Policy Statement for additional information.

How Fisher Investments Europe discharges its responsibilities under the UK Stewardship Code of the Financial Planning Council.

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*As of As of 31/03/2022 Fisher Investments had over $19 billion USD in its ESG/SRI asset under management.

In accordance with Fisher Investments Europe Limited’s (FIE) shareholder engagement policy, please review the proxy voting reports provided on this page for the annual disclosure on how such policy has been implemented for the previous year. As noted in such policy, the proxy voting reports only include data for FIE’s clients who have authorized and directed FIE to vote proxies. Only certain Fisher Investments Institutional Group clients have given FIE such authorization and direction. Therefore, there is no proxy voting report (and therefore no annual disclosure under FIE’s shareholder engagement policy) for non-institutional clients of FIE.