April 2019

Introduction

This Policy details our approach to ESG into our investment process.

We believe that environmental, social, and corporate governance (ESG) issues can affect the performance of investment portfolios (to varying degrees across companies, sectors, regions, asset classes and through time) and ESG factors may be potential indicators of management quality and operational performance. Coupland Cardiff has a structured yet flexible approach to incorporating ESG into the investment process. This allows us to effectively integrate the firm’s ESG efforts alongside the investment strategies, which we believe will achieve the best long term asset growth for our investors. Aside from companies that manufacture controversial weapons such as biological and chemical weapons, cluster bombs, anti-personnel mines or nuclear weapons, as general rule we will not exclude any particular investment or industry based on standardised ESG factors and a “one size fits all” approach. We invest in multiple countries (many developing), and our assessment will take into account ESG best practice whilst acknowledging sector and individual company differences due to local laws and regulations, cultural differences and stage of national integration of ESG when making investment decisions.

What is considered in the investment process?

This will vary by the country, industry and company under review though in all cases we consider where the following factors are relevant and can have material impact on stock performance. During our meetings with companies, as part of our regular investment processes, we may discuss ESG factors, where relevant.

Environmental: Pollution, site management/consideration, greenhouse gas emissions, climate change, habitat protection, recycling, water.

Social: Human/employee rights, working conditions, health and safety, firm-employee relations, child/forced labour, conflict zones
Governance: Board composition, independence, transparency, compensation and accountability, shareholder rights and relations, cyber security, protection of personal data, corruption.

Reporting

We report annually on our activities and progress on implementing the PRI according to the PRI reporting framework. We do not currently publish details beyond PRI reporting requirements, but are willing to provide more detail to clients and prospective clients upon request.

United Nations - Principles of Responsible Investment

As part of our ongoing commitment to integrate ESG factors, Coupland Cardiff became a signatory to the United Nations-backed Principles of Responsible Investment Initiative (UN PRI), further details can be found at https://www.unpri.org. The UN PRI is a network of those in the investment community who work together to ensure that ESG considerations are integrated into the investment process.

Coupland Cardiff and are committed to incorporating the 6 Principles of Responsible Investment (https://www.unpri.org/pri/what-are-the-principles-for-responsible-investment). As a signatory to the Principles, we as publicly commit to adopt and implement them, where consistent with our fiduciary responsibilities. We also commit to evaluate the effectiveness and improve the content of the Principles over time. We believe this will improve our ability to meet commitments to beneficiaries as well as better align our
investment activities with the broader interests of society.

All partners and employees of Coupland Cardiff are required to conduct their duties in a responsible manner and in accordance with the following:

To aim to grow the assets under our management for the benefit of our investors

To act as a responsible steward of our investors capital

To integrate Environmental, Social and Governance considerations into the investment decision making
process in a cohesive and considered manner in line with the 6 Principles of Responsible Investing
(https://www.unpri.org/pri/what-are-the-principles-for-responsible-investment).

To provide transparency to our clients where requested