Sustainable, Responsible &/or ESG Policy:

1.Integration.

• Integrated into the investment process is a base-level ESG assessment which allows the Investment Manager, using a combination of external data, internal data and proprietary data modelling to assess investment opportunities on an absolute and relative basis;
• Bespoke integration processes are used to consider ESG risks and opportunities in the investment process;
• Risk monitoring includes ESG considerations in equity portfolio risk reports;
• Performance against Aviva Investor’s broader ESG objectives is embedded into the Investment Managers’ annual evaluation and remuneration framework.

2.Active Ownership and Stewardship

• The Investment Manager undertakes extensive proactive and reactive engagement with management and boards of issuers and borrowers to monitor ESG practices and encourage best practice. Where ESG risks are identified within an individual company, and it has not responded to a period of engagement to reduce them, the Investment Manager may use the ESG analysis, alongside other parts of the investment process to support a decision to reduce or remove exposure to that company where doing so remains consistent with the objectives and strategy of the Fund. Further details are available in our Annual Responsible Investment Review https://www.avivainvestors.com/en-gb/individual/about-us/responsible-investment.html
• Aviva Investors publishes annual proxy voting guidelines and a UK Stewardship Code compliance statement providing details of the responsible investment approach and outlining views on ESG best practice. The Investment Manager will vote globally at all shareholder meetings that it has the legal right to do so and where costs are not prohibitive. It will endeavour wherever practicable, to recall lent stock prior to contentious shareholder meetings when this is considered in the Funds’ best interests.
• The Investment Manager is committed to transparency through timely publication of voting records and reporting of engagement activities, further details of which are available in our Annual Responsible Investment Review https://www.avivainvestors.com/en-gb/individual/about-us/responsible-investment.html.

Process:

Investment integration in the Aviva Investors MAF Core range

• The ESG team works in collaboration with the Multi-asset & Macro team to contribute to the formationof our macro House View and idea generation, such as the tactical asset allocation decisions.
• ESG is embedded into all the actively managed Aviva Investors funds that the MAF ranges invest into.

ESG factors are considered alongside a range of financial metrics and research.

• Where the Funds invest through other active funds managed outside of Aviva Investors, the ESG policies and procedures of the underlying funds will be assessed as part of the fund selection process.

Leaders in active ownership 

We believe that meaningful engagement with companies is a more powerful tool than exclusion. We therefore seek to hold to account the companies that we own within the MAF ranges. This is exemplified by our strong voting and engagement track record. For example, in 2022 Aviva Investors:

• Voted at 6,732 shareholder meetings on 73,438 resolutions and voted against management 27% of thetime. When it came to pay proposals, we voted against management 49.1% of the time.
• Engaged 3,328 times with 2,192 companies to help drive positive change.
• In our annual responsibility investment review, we have evidenced the outcomes we have delivered,with more than 50 case studies showing how companies have made positive changes on issues rangingfrom women’s representation on boards, plastics in the ocean, protecting world heritage sites andclimate change.

We do, however, have a Baseline Exclusions Policy which outlines the sectors in which investment is prohibited across our entire fund range (e.g. Controversial Weapons, Civilian Firearms, Coal and Tobacco).

Integration of ESG into passive building blocks 

All the securities in the passive index are given a score of 1-10 based on our proprietary ESG score, a product of our ESG Proprietary Tool1.

We use our ESG Proprietary tool to assess the relative importance of ESG factors for the companies within each sector to identify where the ESG characteristics of a company may result in outperformance. These ESG Proprietary tool scores (which use a combination of inputs from externally sourced data as well as our own voting data) are considered a core part of the investment decision-making process and help identify potential sustainability risks for the companies we invest in. A low score denotes poor ESG credentials, while a high score indicates good ESG credentials. The ESG score is based on third-party data as well as our own research. We then look to optimise the portfolio’s aggregate ESG score by allocating more to companies with good ESG credentials and less to companies with poor ESG credentials.

1 Our proprietary tool emphasises the ESG factors which we determine are most closely correlated to potential financial outperformance. Accordingly, it should not be used as a comprehensive measure of the sustainability risks (or the overall ESG quality/credentials) of a portfolio. ESG data for Benchmarks and Portfolios is reliant on: (i) data provided by third party data providers; and (ii) AI and third-party proprietary models. Data from these third-party data providers or used in our proprietary models may be incomplete, inaccurate or unavailable. As a result, there is a risk that AI may, from time to time, incorrectly assess a security, issuer or index. There is also a risk that AI, or the third-party data providers on which we may depend, may not interpret or apply the relevant ESG characteristics correctly.

To make sure that we do not deviate too far from the index we have set several constraints:

• A 0.25% Tracking Error relative to the index (MSCI World Index);
• Any company in the index cannot be increased or decreased by more than 0.50%;
• Any sector in the index cannot be increased or decreased by more than 1.00%;
• Any geographical region cannot be increased or decreased by more than 1.00%; and
• We have a hard exclusion on certain sectors like coal, cluster munitions and landmines.

The process is reviewed on a quarterly basis.

Resources, Affiliations & Corporate Strategies:

In-house resources, roles and responsibilities

The Sustainable Investing function at Aviva Investors contains 40+ specialists within several teams that report to the Chief Sustainable Investing Officer to support the wide-ranging activity that underpins our sustainable investing approach. 

The Sustainability Strategy team leads and co-ordinates sustainability strategy, commercialisation of our sustainability capabilities at firm level and institutional governance matters.

The integration and stewardship team covers all asset classes, including credit, equities and multi-asset in Public Markets, and real estate, private debt and infrastructure in Private Markets. The team oversees the integration of environmental, social and governance (ESG) factors into the investment process across Aviva Investors’ spectrum of liquid and illiquid assets. This includes proprietary quantitative scoring, bottom-up ESG corporate research, top-down thematic research and outcome related analysis. The team is also responsible for conducting stewardship activities with our clients’ investments; exercising proxy voting rights and engaging with investee companies and borrowers to enhance long term shareholder value. Our ESG integration and stewardship teams work closely, and have multiple touch points, with our public and private investment functions. This helps to ensure close communication and collaboration between our investment professionals and sustainability analysts. 

Our Sustainable Investments team oversees Aviva Investors’ sustainable funds. The team develops and evolves strategic frameworks that respond to the changing landscape of sustainable markets, ensuring tangible outcomes for clients. It works to enhance the philosophy and processes underpinning existing sustainable funds, including the development of supporting data, quantitative research models, and the measurement and delivery of sustainability impacts. The team also supports sustainability research across asset classes and plays a key role in the development of new sustainability and impact strategies.

We also have a team that works closely with our parent company, Aviva, to deliver on the investment components of the Aviva Sustainability Ambitions. This relates to climate, nature and social objectives and involves defining sustainability objectives and action plans. In addition, the team is responsible for building investment solutions to deliver on sustainability objectives as well as developing net zero and nature investment analytics and tools and the solutions linked to these capabilities.

Aviva Investors works in collaboration with the Group Public Policy team to engage with national governments, regulators, standard-setters and international institutions to develop and advocate for policy measures that aim to create more sustainable capital markets.

External resources/responsibilities

As an active manager we source information that, alongside investment research, can support regulatory and client reporting activity. We source sustainability data from a variety of data providers, which we review regularly. We hold regular reviews with our largest third-party data provider to discuss how continuous improvements could be made to data or research outputs. Additionally, we hold ad-hoc meetings to discuss broader trends in sustainability.

Our market data team is an independent function that manages commercial relationships and renewals with our market data service providers. This function operates an hourglass model that sits between the business and suppliers. There are regular reviews in place to check that contracts are still meeting business needs, including service quality, availability and accuracy of data.

Our investment engineering team is responsible for several models and analytical dashboards, using data science techniques to derive greater value from vendors, NGOs and proprietary sourced datasets. Dashboards provide transparency into the construction of models. Integration of model outcomes into our portfolio management tool allow analysts and fund managers to take these insights in consideration.

Examples of data providers used:

Data vendors – Large-scale providers with multiple datasets and deep coverage

• MSCI
• LSEG
• Trucost Analysis – S&P Global

Data specialists – Innovative and niche providers with specific scope and high quality

• BoardEx
• IBAT
• Iceberg Data Lab
• Auquan

NGOs - Specialist analysis, often not for profit; detailed datasets with issuer scope aligned to purpose

• CDP
• Climate Bonds Initiative

To support us in making voting decisions on thousands of meetings a year, we subscribe to research from third-party providers. Our main provider for voting services since October 2023 is Glass Lewis. We also subscribe to IVIS research (provided by the Investment Association) and MSCI. We use research for data analysis only and do not automatically follow research provider voting recommendations. We also receive recommendations from Glass Lewis based on our own policy, which we can override in consideration of other factors, including internal views, additional context provided in external research, and company explanations.

Briefly describe governance structure and responsibilities

The Aviva Investors boards, including Aviva Investors Holdings Limited, Aviva Investors UK Fund Services Limited, Aviva Investors Luxembourg (Lux.) Supervisory, Aviva Investors Lux. Management Company and Aviva Investors Lux. SICAV, receive regular reporting on key sustainability risk management metrics throughout the year. These include the results of sustainability risk assessments, do no significant harm indicators, climate value at risk and carbon intensity figures. These give the boards oversight of our approach to sustainability risk management and of how we are delivering on our clients’ sustainability preferences. In 2024, the Boards also received deep dives into climate metrics and the commercialisation of sustainability capabilities. We continue to develop and refine our approach to Board reporting to support effective oversight of our stewardship activities, including reviewing metrics to ensure they remain current and providing narrative and rationale to contextualise the sustainability information our boards receive.

The Aviva Investors Holdings Limited Board sets our overarching approach for sustainability. Responsibility for executive management of this approach is delegated to the CEO. The CEO is provided with advice and support from the executive team, which includes our chief sustainable investing officer.

The chief sustainable investing officer is responsible for proposing and implementing our sustainability strategy, oversight and execution policies and commitments at a firm and product level, and oversight of compliance with the relevant internal controls environment. Our sustainability strategy director chairs, on behalf of the chief sustainable investing officer, the sustainable investing business oversight committee, which includes representation from across the business. This committee ensures sustainable investing policies and procedures are aligned with firm-wide policies and procedures, and that the business is embedding client preferences in its approach to sustainability.

Working collaboratively with investment desks, the chief sustainable investing officer’s team is responsible for ESG integration and stewardship in public markets, ESG integration and stewardship in private markets, development of sustainable funds, development of sustainability analytics and tools, and sustainability strategy and governance.

Our analysts, regulatory development and client-facing teams monitor ongoing sustainability developments, with any revisions to policies subject to final approval by our policy approval group.

List related affiliations, memberships, and involvement with groups such as UNPRI / IIGCC / CA100+/CDP

The list below shows collaborative initiatives in which Aviva Investors participates as an active member, where we have participated in events or where we have indicated support for a statement as a signatory. More information regarding any of the initiatives or statements can be provided on request. This list is as of 31.12.2024 and can be found in our 2024 Annual Sustainability Review here: Policies and documents - Aviva Investors

Founding member

• Collaborative Sovereign Engagement on Climate Change
• Investor Action on Anti-Microbial Resistance
• Investor Initiative on Hazardous Chemicals (IIHC)
• Investor Initiative on Human Rights Data (II-HRD)
• Sustainable Stock Exchange Initiative
• UN Principles for Responsible Investment (UN PRI)
• World Benchmarking Alliance (WBA)

Memberships and working groups

• 30% Club UK Investor Group
• Advance
• Aldersgate Group
• Asian Corporate Governance Association (ACGA)
• Benchmarking Human Rights Performance
• Bondholder Stewardship Working Group
• Chatham House
• Climate Engagement Canada (CEC)
• FAIRR – Biodiversity, Waste and Pollution Programme
• FAIRR – Protein Diversification
• FRC UK Stewardship Code 2020
• GC100 and Investor Group – Remuneration Reporting
• Guidance
• GFANZ Policy Workstream
• Global Impact Investing Network (GIIN)
• Global Institutional Governance Network (GIGN)
• Good Work Coalition
• Global Real Estate Sustainability Benchmark (GRESB)
• Institutional Investors Group on Climate Change (IIGCC)
• Investor Policy Dialogue on Deforestation (IPDD) Initiative
• Labour Rights Investor Network (LRIN)
• Nature Action 100
• Net Zero Asset Managers Initiative (NZAM)
• ShareAction – Chemical Working Group
• Sovereign Debt Advisory Committee
• The Investment Association
• The Investment Association – Climate Change Working Group
• The Investment Association – Remuneration and Share Schemes Committee
• The Investment Association – Sustainability and Responsible Investment Committee
• The Investor Forum
• TheCityUK Sustainable Finance Forum
• Transition Finance Market Review Expert Advisory Panel
• UN Principles for Responsible Investment Sustainable Systems Investment Managers Reference Group
• VBDO (Vereniging van Beleggers voor Duurzame Ontwikkeling) Investor Statement on Plastics

Signatories and collaborative events

• Access to Medicine Foundation
• Carbon Disclosure Project (CDP)
• Climate Action 100+ (CA100)
• Global Investor Statement to Governments on the Climate Crisis
• Partnership for Carbon Accounting Financials (PCAF)
• Planet Tracker Plastic Pollution Investor Statement
• Rathbones Statement on Reporting Requirements re: Section 54 of UK Modern Slavery Act

SDR Labelling:

Unlabelled - promotes sustainable characteristics (has CFD)

SDR Literature:

• Consumer Facing Disclosure - I
• Consumer Facing Disclosure - II
• Consumer Facing Disclosure - III
• Consumer Facing Disclosure - IV