RI Annual Report 2023



Implementation of Principles for Responsible Investment (PRI)

Principle 1: We will incorporate ESG issues into investment analysis and decision-making processes.

• We have a RI policy that is applicable to all our products 36 • We have a dedicated ESG research function whose analytical process is subject to constant development. We run and maintain an internal ESG scoring platform • We source ESG research from brokers and specialist research providers • We collaborate with academic and other researchers to further knowledge on ESG • We run a series of workshops internally on ESG issues, and we teach investment professionals how to integrate them in their analysis • We work closely with PMs running ESG-enhanced products to enhance the integration of ESG into their investment processes

Principle 2: We will be active owners and incorporate ESG issues into our ownership policies and practices.

• We publish a RI policy which extensively covers active ownership and has the Principles at its core • We vote our holdings and frequently use the vote as an engagement tool • We have a track record of filing, co-filing or supporting shareholder resolutions with a long-term ESG focus • We have extensive engagement capabilities and an award-winning engagement program • We are active participants in policy development, regulation and standard setting through bodies such as the SASB Investor Advisory Group, TCFD pilot group, and Swedish nomination committees • We participate in numerous collaborative engagement initiatives, such as Climate Action 100+ and the Corporate Human Rights Benchmark (CHRB) • Investment managers are encouraged to include ESG engagement in their reporting

Principle 3: We will seek appropriate disclosure on ESG issues by the entities in which we invest.

• We advocate for standardised reporting on ESG issues and are active and prominent supporters of SASB • We consistently encourage companies to include ESG issues in their annual reports • We are a part of the TCFD pilot group, and systematically promote better climate disclosure across industries

Principle 4: We will promote acceptance and implementation of the Principles within the investment industry.

• We include indicators related to the Principles in performance evaluation and incentives • We extensively collaborate with service providers to help them meet our ESG requirements • We support regulatory and policy developments that promote the Principles

Principle 5: We will work together to enhance our effectiveness in implementing the Principles.

• We collaborate with selected fellow investors to enhance our practices • We participate and lead various collaborative initiatives, see list under Principle 2

Principle 6: We will each report on our activities and progress towards implementing the Principles.

• Our RI annual report contains a section that explains how ESG issues are integrated in investment practices • Our RI annual report contains a section that details active ownership activities • We report on achievements related to the Principles in our RI annual report • We seek to determine the impact of integration activities throughout our portfolios, for example by benchmarking carbon footprint and SDG exposure

36) The RI Policy applies to all Nordea-branded investment strategies, with the exception of any holdings by such strategies in external funds and index derivatives and selected discretionary mandates on clients’ request.

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