Sustainable, Responsible &/or ESG Policy:

The BlueBay Impact-Aligned Bond Fund aims to invest in securities of issuers whose core economic activities offer investment opportunities and contribute solutions to address major environment and social challenges. The investment team believes that there is an opportunity to evolve the impact investing market by delivering a strategy that invests predominantly in public and liquid corporate debt securities with a focus on positive intentionality. The Strategy will also have the potential to gain exposure to environmental, social and governance (ESG) labelled securities (of corporate or sovereign issuers) where these meet the strategy’s sustainability themes.

The Fund applies an ESG integration approach, considering ESG factors and risks at issuer, sector/thematic and portfolio level. However as it is an ESG focused strategy, how it applies the outcome of the issuer ESG evaluation analysis to what can be invested in will vary from a strategy that is not ESG focused.

Beyond the ESG integration approach, we have also incorporated consideration of ESG risks in terms of adoption of formal ESG investment criteria. These are implemented and maintained by our compliance function, where lists of restricted names are sourced from our third party ESG vendor, and coded into our investment trading system.

As to our process for considering ESG opportunities for the Fund, the primary way is through our sustainability themes framework which focuses on economic activities, although the issuer ESG evaluation framework does also capture potential ESG opportunities arising from improve ESG conduct.

Sustainability themes

The sustainability themes developed target positive contribution to people and to the planet through selecting issuers whose core economic activities offer investment opportunities and contribute to addressing environmental and social challenges. The People and Planet sustainability themes the Fund invests in are currently as follows:

• Ensuring good health, safety and well-being
• Achieving an inclusive society
• Building knowledge and skills
• Promoting sustainable mobility and infrastructure
• Promoting clean and safe energy
• Enabling a circular economy
• Ensuring clean and plentiful water

Sustainability themes may change over time depending on where RBC BlueBay FI Platform identifies developments in sustainability trends affecting people and the planet.

Sustainability qualification framework - eligible issuers and securities

Issuers and securities can qualify for investment in the Fund via one of two possible routes:

1. Consideration of what the core business activity of a company is:

Only corporate issuers can qualify under this category, but investments can be in vanilla bonds or ESG labelled issuances (which can include but are not necessarily limited to use of proceeds securities such as green, social or sustainability/SDG bonds, or in specific instances, to sustainability linked bonds)
Alignment of the issuer’s economic activity with material exposure to relevant sustainability themes is assessed using a range of ‘positive’ materiality indicators, including but not limited to:

• • Revenues
  • Profits
  • Market share and position
  • Capex / opex
  • Material value driver

An issuer does not have to meet all the above ‘positive’ materiality indicators to qualify for investment.

The sustainability profile of an issuer’s entire economic activity is considered in order to exclude those with materiality exposure to activities that significantly harm the Sustainable Investment objective of the Fund. Some of the areas of economic activities which we consider to significantly harm the Sustainable Investment objective of the Fund are formally excluded from investment. Additionally, some of the conduct related activities of issuers which are considered to significantly harm the Sustainable Investment Objective of the Fund are also formally excluded from investment.

2. Consideration of what the activity is being funded/supported by the security being issued:

this will often be limited to ESG labelled issuances, but can include both corporate as well as non-corporate issuers such as sovereign, supranational and agency (SSAs) issuers.

The current scope of investments in ESG labelled bonds (of corporate or sovereigns, supranationals and agencies or SSA), is largely confined to use-of-proceeds issuances including, but not limited to, green, social and sustainability bonds, earmarked to projects which meet at least one of the sustainability themes. On a case by case basis, investments in outcomes-based labelled issuances such as sustainability-linked bonds may be permitted.

Alignment of the use of proceeds for ESG labelled issuances with material exposure to relevant sustainability themes is assessed using a range of ‘positive’ materiality indicators, including but not limited to:

• • Scope of the eligibility projects criteria framework
  • Extent to which there is new financing activities

In some instances, investments may occur in vanilla bonds of non-corporate issuers qualifying in this way where the entity has a unique legal organisational and governance structure such that the activities being funded or supported meet our sustainability themes.

An issuance does not have to meet all the above ‘positive’ materiality indicators to qualify for investment.

The sustainability profile of the underlying issuer of the security’s entire economic activity is considered in order to exclude those with materiality exposure to activities that significantly harm any positive sustainability impact the Fund is looking to have.

Beyond its sustainability themes, the Fund’s ESG characteristics is achieved through the application of binding ESG requirements resulting from: ESG exclusions/screens (Corporates1,2 – controversial weapons (any production – cluster munitions, landmines, chemical/biological weapons, depleted uranium, nuclear weapons, blinding lasers, non-detectable fragments, incendiary weapons), adult entertainment (>10% revenues – production/distribution/retail), alcohol (>10% revenues – production/distribution/retail), conventional weapons (>10% revenues – production of systems and components), fossil fuels related: arctic oil & gas (0% revenues – production) / conventional & unconventional oil & gas (>5% revenues - production) / oil sands (0% revenues – extraction) / thermal coal* (installed capacity >10,000 MW, mining/power >5% revenues/operations), gambling (>10% revenues – operations/support), nuclear energy* (>5% revenues – mining/production/supply), tobacco (any production, >5% revenues – distribution/retail)) / ESG norms-based screening (ESG norms-based exclusion screens: Corporates1,2 – non-compliance with of UN Global Compact principles (fail), ESG controversy exposure (worst); Sovereigns1,3: controversial jurisdictions (Financial Action Task Force (high risk), UN Security Council Sanctions), Freedom House Index (‘not free’), UN conventions and treaties: corruption convention (not party to) / torture and punishment convention (not party to/no action/not ratified) / Paris Agreement (no action/not ratified), and ESG integration which can additionally restrict issuers depending on the outcome of the ESG evaluation (Excludes issuers with 'very high' Fundamental ESG (Risk) Rating (systematic) and excludes issuers with 'high' Fundamental ESG (Risk) Rating (case by case)). The Fund shall also implement ESG engagement as part of its stewardship commitment, which means dialogue which not only consider ESG risks (those which are likely to be investment material) but also ESG factors.

Notes: 1 As determined by our third party ESG information provider, MSCI ESG Research. Further information is available from MSCI ESG Research; 2 As determined by a) our third party ESG information provider, MSCI ESG Research. Further information is available from MSCI ESG Research, and/or b) Norwegian Government Pension Fund Global/NBIM ESG Ethical Guidelines. Further information is available from NBIM; 3 As determined internally by Investment Compliance. Further information is available upon request.

* Exceptions permitted in specific instances for power utility companies in the case of transmission/distribution/capacity thresholds. Further information is available upon request.

Process:

In order to understand the degree of ESG integration in the Fund, we have detailed the extent to which ESG factors are considered under each of the following:

i. Idea Generation
ii. Buy Discipline
iii. Portfolio Construction & Risk Management
iv. Sell Discipline

i. Idea Generation

ESG dimension of idea generation
ESG considerations are fundamental to the Fund, and structurally influence idea generation beyond financial considerations. The Fund explicitly seeks to invest in fixed income securities which explicitly contributing to addressing major environmental and social challenges. This comes into play in different ways as outlined below:

• ESG screening (issuer level)
• ESG sustainability assessment (issuer and issue level)
• ESG integration (leading to further exclusions where minimum ESG thresholds not met) – general framework picked up in the ‘conventional financial dimension of idea generation’ part
• ESG stewardship/engagement

(Conventional) Financial dimension of idea generation
We believe that our proprietary research gives us our investment edge and as such we have a deeply resourced team of high-quality, experienced Alpha Specialists covering the investment universe. While providing a framework for our Alpha Specialists, the Investment process does not articulate how alpha decisions should be made, nor is it explicit in setting a time horizon for any decision. Different alpha decisions require different analysis at different times and time horizons can be dictated by ever changing inputs. Alpha Specialists are however always required to consider fundamentals (including ESG factors), valuations, technical and ESG factors when analysing any alpha source.

Fundamentals:

• Both macro and credit issuer alpha sources are analysed by individual specialists based on their fundamentals.
• Macro analysis is conducted on a series of macro alpha sources with respect to term structure, sector and currency selection.
• Credit analysis is conducted on all screened issuers. Credit analysis is divided between sovereign credit analysis and non-sovereign credit analysis.
• Each Alpha Specialist has specific sector responsibilities. They determine credit worthiness for each individual issue based on a variety of factors:
  • Sovereign credit review: assesses an issuer’s fiscal characteristics, historical performance, growth outlook, external competitiveness, leverage statistics (e.g. debt/GDP), political credibility and geo-political event risk;
  • Corporate credit review: assesses an issuer’s industry characteristics, historical performance, corporate strategy, competitiveness issues, leverage statistics (e.g. debt/EBITDA), management credibility and event risk;
  • Cash flow analysis: evaluates the cash flow available for debt servicing, working capital and capital expenditure requirements, and liquidity and debt amortisation schedules; and
  • External research: is also reviewed and incorporates information from rating agencies as well as fixed income and equity research.

ESG – integration (issuer ESG evalutions)
We consider ESG risks as part of our credit assessment. The individual credit analyst is responsible for assessing the ESG risks of the issuer in question and will utilise both external research and our RI team to form an opinion of the issuer’s oversight and management of ESG factors. Our ESG views are recorded in our Alpha Decision Tool (ADT) which provides the basis for monitoring and analysis of all our investment decisions with supporting research notes stored in our Alpha Research Tool (ART).

To this effect, alongside conventional credit analysis of an issuer, we have developed an issuer ESG evaluation framework for use by credit analysts as part of their research process. The issuer ESG evaluation process enables our credit and RI team to express their ESG views on an issuer. The output of this analysis is taken into account by portfolio managers when constructing their portfolios and making investment decisions. Whilst we source ESG data on issuers from external providers we consider them an input into our own analysis (outside of the case where there are explicit ESG exclusions in place), as we believe it is critical we are able to formulate our own independent views.

There are two important ESG metrics resulting from the BlueBay Global Fixed Income Platform ESG evaluation framework:

• A Fundamental ESG (Risk) Rating which indicates our view on how well the issuer manages its material ESG risks. There can only be one Fundamental ESG (Risk) Rating per issuer (e.g. at the ticker level) across BlueBay.
• An Investment ESG Score which reflects an investment view on the extent to which the ESG risk factors are considered relevant to valuations. The Investment ESG Score is specific to a decision on a security/instrument level (e.g. at the ISIN level). Investment teams may assign different Investment ESG Scores meaning there may be multiple Investment ESG Scores for a single issuer. In this way we can allow for different ESG investment materiality over varying time frames and risk-reward profiles. This Investment ESG Score is solely owned by the credit analyst/portfolio manager.

We have purposely disaggregated the management of ESG risks from the investment materiality as we believe this enables us to better understand the extent to which ESG risks are indeed investment material, and in which circumstances. The two-resulting ESG metrics are recorded appropriately and are being fed into the Alpha Decision Tool (ADT), an in-house platform which enables investment teams to capture and monitor trade ideas. In addition, credit and ESG research is stored together in our central in-house research platform, the Alpha Research Tool (ART). ESG data and insights also feed through to Portfolio Insight (Pi), another proprietary tool enabling our investment teams to view other related ESG metrics for their portfolios and associated benchmarks.

In our view, this level of transparency is especially important in fixed income as the asset class operates differently compared to the equity market, and as a result ESG factors may play out in different ways for various reasons. We believe such insights can inform on our wider knowledge and understanding of ESG fixed income dynamics, and ultimately allow us to make more informed investment decisions.

The two internal ESG metrics enable credit and RI analysts to express their ESG views on an issuer and the securities they have issued. Furthermore, the output from this analysis is considered by the portfolio managers during the portfolio construction phase of the investment process. Issuers who are assigned a ‘Very High Fundamental ESG (Risk)’ Rating based on the ESG evaluation framework are excluded from this Fund.

Please note: In the context of the impact-aligned bond Fund, how this has been applied is that we have set a minimum Fundamental ESG (Risk) Rating for an issuer is set in order for it to be considered an eligible investment.

Specifically, where an issuer is assigned ‘very high’ are excluded; and those with the next worst - ‘high’ - which do not meet the qualifying criteria to be acceptable (e.g., evidence an improving ESG performance trajectory or show willingness to improve/where we have an engagement programme to promote positive change) are also excluded. As part of the ESG integration assessment, there is an assessment of good governance, where any issuer deemed to have a ‘very high’ Fundamental ESG (Risk) Rating on the governance pillar of the proprietary issuer ESG evaluation framework is automatically assigned a ‘very high’ Fundamental ESG (Risk) Rating overall at the entity level, and consequently not eligible from investment.

Valuations

• At this stage of our investment process we examine relative value as well as risk and return characteristics of each investment opportunity. We seek to place our fundamental analysis, with respect to macro alpha sources and credit issuers, within a market context.
• Our issue analysis assesses the ranking of an issue in the capital structure, the levels of covenant and collateral protection and the relevant legal framework, while relative value analysis determines market assumptions embedded in prevailing market prices. It also measures relative value versus comparables, forms an expectation of returns versus volatility, and assesses the credit default swap (CDS) basis and any cross-currency opportunities.

Technicals
We conduct a technical analysis in which we assess the technical elements that will influence the price action in a particular bond. In doing this, we analyse:

• Bond characteristics: currency of issues, issue size, syndicate, liquidity and the investor audience; and
• Supply/demand factors: investor and “street” positioning, projected issuance, potential scarcity premium (repo) and index composition and rebalancing

ii. Buy Discipline

Decision Outputs: Every alpha source is assigned a pricing reference. As part of the idea generation Alpha Specialists are required to score each of the aforementioned drivers on a +3 (most bullish) to -3 (most bearish) scale, dependent on their expected impact on repricing of the alpha source. These scores then help inform the overall investment conviction score, which is expressed on the same +3 to -3 scale and is reflected for every alpha source in our proprietary ADT. By using the same scoring system for all investment decisions made on the BlueBay Global Fixed Income Platform, we are able to design investment solutions that meet our client’s needs and span various asset classes.

Alpha specialists are expected to maintain their investible conviction score in the ADT, along with a target and loss review level, an investment summary rationale and an assessment of risk factor associated with their investment idea. They are also expected to make regular comments relating to changes in conviction, alpha source behaviour, significant news flow or changes in target / loss review levels.

The ADT puts structure and discipline around the investment process by:

• Capturing all decisions made by our Alpha specialists and providing us with the raw materials to construct portfolios
• Communicating decision changes to the broader investment team
• Monitoring price levels (using a live price feed) against target and stop loss levels
• Measuring decision success which allows us to link compensation of risk takers to alpha generation in alpha sources
• Analysing decision quality and providing a feedback loop to improve the process
• Providing transparency for clients

More detailed research backing our Alpha source decision outputs in ADT are stored in our Alpha Research Tool (ART), which is directly linked to the ADT.

Tom Moulds is the ‘lead PM’ so he has the final say on which issuers/issues will be included in the fund. As with all our funds, however, we work with a team-based approach and incentivise strong input and debate from all members of the team: analysts, PMs, IPMs etc. The management team of Tom Moulds, My-Linh Ngo, Harrison Hill and Robert Lambert act as portfolio constructors, harnessing the ADT to build a portfolio using the convictions and trade ideas from the global analyst base.

Please note: beyond conventional financial parameters considered, the ongoing ESG/ sustainability qualification/eligibility of the investment (i.e. in terms of their continued compliance with the ESG screens, sustainability themes, and minimum ESG integration thresholds) are also factors which will directly influence buying decisions.

iii. Portfolio Construction & Risk Management

Portfolio Construction
Every Strategy and portfolio utilises the Alpha Source Conviction Scores stored in the ADT in conjunction with the Product Design, in order to determine portfolio positioning. Position sizing is assisted by proprietary Quantitative Tools in order to achieve a degree of consistency in position sizing. The objective of Portfolio Construction is to make optimal use of Alpha Source outputs (+3 to -3), in light of the product design, while taking into account risk inputs, including liquidity scores and portfolio sensitivities. It is also an objective to minimise alpha slippage in implementation. Put simply, the alpha is being generated by the investment specialists and the aim of portfolio construction is to get as much of that alpha into portfolios as possible, while controlling risk.

The majority of the alpha delivered in our portfolios is typically derived from our alpha sources while the remaining components are attributable to portfolio construction decisions.

We are mindful of trading activity and trading portfolio positions typically occurs when a new alpha source decision is introduced, or there has been a change in an existing alpha source decision. Trading can also result from cash flow into / out of a portfolio, new issue of securities, a perceived change in volatility, or as a result of an overall portfolio risk increase / reduction.

Portfolio construction and trading are at all times governed by our policies related to side by side management of similar portfolios, aggregation and allocation of trades as well as order execution policies. Compliance with investment and regulatory guidelines is reinforced by our compliance monitoring process undertaken through the Charles River Investment Management System (Charles River) Portfolio risk is monitored on an absolute basis by BlueBay’s Risk and Performance Team using our risk management system, RiskManager (from MSCI).

ESG risk oversight is provided across the BlueBay Global Fixed Income Platform strategies and investment desks through continual analysis and monitoring of firmwide ESG risk exposure. This involves the ESG investment team interacting with investment risk colleagues, utilizing investment exposure data, as well as conducting ad-hoc ESG analysis as deemed appropriate. The ESG Investment Working Group (IWG) is charged with the oversight of and ensuring ESG integration within our investment practices. The ESG IWG sets a work programme annually, with progress against these points monitored at each monthly meeting.

iv. Sell Discipline

Positions may be sold when loss review levels or profit target levels, which are set when implementing any risk position in the portfolio, are hit. If a position has hit its loss review level, the idea generator reassesses their decision and looks once again at the fundamentals, technicals and valuation to ensure that their rationale and conviction score remains valid. At that point, the analyst decides either to run the position or to close off the position. It is possible that the team still believes in the rationale for the position but that it has become riskier than initially expected.
In that case, the team may decide to reduce the size of the position. They then size it appropriately with respect to the potential downside if they are wrong.

Typically, the loss review level is set at half of the profit target. There is some flexibility, however, and stop loss levels can be tightened or loosened according to market volatility, our level of risk/conviction on a specific position or to take into account specific anticipated events. Profit targets and loss review levels are, in general, relative targets, i.e. relative to the broader market performance. This loss review discipline applies across all decisions the team implements in portfolios. In formulating the loss review level, decision makers are encouraged to consider carefully where other market participants will have their stop loss positions to avoid closing a position too late or too soon.

NOTE: beyond conventional financial parameters considered, the ongoing ESG/sustainability qualification/eligibility of the investment (i.e. in terms of their continued compliance with the ESG screens, sustainability themes, and minimum ESG integration thresholds) are also factors which will influence any divestment decisions.

Resources, Affiliations & Corporate Strategies:

In terms of third-party portfolio rating measurements, BlueBay Global Fixed Income Platform sources issuer ESG data from a number of specialist third-party providers and utilises other ESG data-related products and services from external stakeholders to help in the ESG integration process, which are made available to the investment teams.

Specifically, we source issuer ESG data from specialist third parties:

• Corporates: MSCI ESG Research, RepRisk, NASDAQ, the Upright Project, Impact Cubed
• Sovereigns: Verisk Maplecroft; MSCI ESG Research, Eurasia Group, NASDAQ

Ultimately the external resources input into our views but do not define them. BlueBay Global Fixed Income Platform uses a combination of internal and external ESG data/ratings/insights to inform on our issuer ESG view, with a trend towards greater focus on our proprietary ESG insights, with the external data as inputs. Whilst we consider third-party insight to be a valuable input in terms of understanding ESG risks and insights, we believe it is critical that we develop our own views on an issuer’s ESG risk exposure. This is particularly pertinent in the case of issuers for which we have access to insights and other resources that go beyond those which data providers may be able to access. Where, however, we understand the methodology and basis for a third-party's views, we can incorporate them in an informed way.

RBC Global Asset Management (RBC GAM) Responsible Investment (RI) team

The RBC Global Asset Management (RBC GAM) Responsible Investment (RI) team is comprised of 17 dedicated full-time employees who sit within the investment platform. The RI team members have a mix of investment, ESG, risk management, data engineering, and legal expertise. Team members’ individual compensation is directly related to RBC GAM’s responsible investment and stewardship activities.

The Head of RI reports directly to the RBC GAM CIO and sits on a number of executive committees, including the RBC GAM Leadership Committee and the RBC Climate Steering Committee, which provides coordination on RBC’s climate strategy and its implementation.

As a centralised function, the RI team’s primary responsibility is to lead responsible investment activities and stewardship across the firm.

Our Approach to Responsible Investment document is reviewed on an annual basis by the Responsible Investment (RI) team, with input on any changes provided by the RBC GAM Leadership Committee (Leadership Committee), and ultimate approval by RBC GAM’s CIO.

RBC GAM’s CIO, CEO, and relevant Boards of Directors oversee the performance of firm-wide strategic initiatives, including responsible investment, on a quarterly and annual basis. Responsibility for strategic initiatives is delegated to the appropriate executives, whose direct annual compensation includes an assessment of performance on those initiatives. In addition, performance on strategic initiatives can also contribute to the overall firm-level performance factor that is applied to all employees’ annual variable compensation. The RBC GAM Leadership Committee has identified the continued enhancement of ESG integration into the investment teams’ processes as a strategic objective for the organisation.

Daily implementation of our Approach to Responsible Investment has been delegated to our RI and investment teams. As such, our RI team members’ individual compensation is entirely related to RBC GAM’s responsible investment and stewardship activities. Our investment teams are regularly evaluated on their teams’ ESG integration processes, including as one component of their annual variable compensation.
Specific executive management oversight responsibilities include:

• The CEO sets the strategic direction of RBC GAM and oversees the firm’s performance of all strategic initiatives and Approach to Responsible Investment. The CIO and the COO report to the RBC GAM CEO.
• The CIO oversees the investment strategies, policies, and performance across all affiliates. The heads of all investment teams and the RI team report to the CIO. The CIO of BlueBay reports directly to the CIO.
• The COO oversees all operational strategies, policies, risks, and initiatives across all affiliates.
• The Head of RI is responsible for all responsible investment activities across RBC GAM, and for the implementation of these strategies by RBC GAM’s centralised RI team.
• The heads of global investment teams are responsible for the establishment and implementation of ESG integration processes for applicable strategies.
• The heads of the institutional and retail businesses oversee product development, with review by a Product Committee and oversight by the CIO and CEO. Review and input on new products is provided by the COO, the Head of RI, and members of the Investment Risk, Investment Policy, Compliance, and Legal teams.

This governance structure was chosen to ensure that the level of oversight of responsible investment and stewardship is commensurate with its importance to RBC GAM’s overall business strategy. The combination of executive oversight and responsibility over these initiatives helps ensure that responsible investment and stewardship is effectively executed and continuously improves.

Bios of the RI team members are provided below:

Melanie Adams: J.D., Law, University of Toronto; B.Sc., University of Waterloo
Melanie is Managing Director & Head of the Responsible Investment (RI) team at RBC GAM and a member of the Leadership Committee. The Responsible Investment team supports RBC GAM’s investment teams in integrating environmental, social and governance factors into the investment process, engages in active stewardship and provides meaningful client reporting on responsible investment. Melanie serves on the Board of Directors of the Responsible Investment Association as Vice-Chair, the Public Policy Committee of the Canadian Coalition for Good Governance, the Policy Committee of the International Corporate Governance Network, in addition to other responsible investment committees. Melanie joined RBC GAM in 2014 and has also held roles in Fund Governance and Strategy, which included evaluating and executing on corporate acquisitions/mergers. Prior to working at RBC GAM, Melanie was Senior Counsel, Litigation for another large financial institution, and Enforcement Counsel at the Ontario Securities Commission.

Research & Policy

Maia Becker: MBA, Rotman, University of Toronto; Master in Forest Conservation, MFC University of Toronto; B.Sc. Queen’s University; GHG Inventory Quantifier (GHG-IQ) and LEED® Accredited Professional (LEED AP)
Maia is Senior Director on the Responsible Investment (RI) team for RBC GAM and leads ESG research and policy as part of the RI team. In this role, Maia works closely with global investment and distribution teams to provide strategic advice, insights and research on the integration of ESG factors into the investment approach, with a key focus on RBC GAM’s approach to climate change and net zero ambition. Maia is a member of the Environmental and Social Committee of the Canadian Coalition for Good Governance (CCGG), and Chair of the Technical Committee for Climate Engagement Canada. Maia first joined the Royal Bank of Canada (RBC) in 2016, playing a lead role in RBC’s environmental and social risk management program. Prior to joining RBC, Maia spent over ten years working with governments, companies, and non-profit organizations leading sustainability strategy, policy, and program development. She has also been recognized as one of Canada's Clean50 2019 for advancing climate risk management within Financial Institutions.

Matt Carthy: CFA, BCom., University of Guelph
Matt is a Senior Analyst for the Responsible Investment (RI) team at RBC GAM, supporting ESG research and policy initiatives. In this role, Matt works closely with global investment teams to provide insights and research on the integration of ESG factors into their investment approach, with a key focus on RBC GAM’s approach to climate change. Prior to joining RBC GAM in 2013, Matt worked in the retail banking arm of RBC, which is where he started his career in 2010.

Sanja Sretenovic: CFA, BCom., McGill University
Sanja is a Senior Analyst on the Responsible Investment (RI) team at RBC GAM, focused on ESG research and policy initiatives. In this role, Sanja works with global investment and distribution teams to provide strategic advice, insights, and research on the integration of ESG factors into the investment approach. Prior to joining the team in 2019, Sanja worked at a large provincial investment management corporation, where she held multiple roles in cross-asset class strategic investment research, global thematic public equity investments, and ESG integration and stewardship. Sanja began her career in the investment industry in 2014.

Equities

Derek Butcher: MBA, Odette School of Business, University of Windsor; Masters in Environment and Sustainability, University of Western Ontario; B.Sc (Hons) – Biological Sciences, University of Windsor
Derek is Senior Manager on the Responsible Investment (RI) team at RBC GAM, responsible for assisting the investment teams with their ESG integration processes, participating in ESG engagements with issuers and overseeing the firm’s proxy voting. Prior to joining RBC GAM in 2015, Derek worked as a researcher for one of the world’s leading responsible investment research providers, conducting ESG research across markets and providing clients with customized responsible investment products. Derek serves on the Board of Directors of the Investor Stewardship Group, in addition to other responsible investment committees. Derek is a CFA® charterholder.

Nureen Nagra: CFA; BComm, University of British Columbia
Nureen is a Senior Analyst on the Responsible Investment (RI) team at RBC GAM, responsible for various RI initiatives including supporting investment teams with ESG integration, conducting RI analysis and research, participating in ESG engagements with issuers and executing on the firm’s proxy voting activities. Nureen joined RBC GAM in 2015 and has worked with retail and institutional clients in varying roles. Prior to working at RBC GAM, Nureen worked with institutional and high-net-worth clients at another large financial institution.

Yousef Abushanab: MSc (International Business) (2016), Maastricht University, Netherlands; BSc (2013), York University
Yousef is a Senior Analyst on the Responsible Investment (RI) team at RBC GAM. Prior to joining RBC GAM in 2017, Yousef worked for a global ESG research and ratings institution in Amsterdam, is where he started his career in 2016. In this role, he conducted research on governance practices of publicly listed companies and assisted with ratings analysis.

Alan Weider: CFA; MEng., (Hons) Chemical Engineering, University of Birmingham; Diploma in Investment Management (ESG), CFA UK
Alan is a Senior Analyst on the Responsible Investment (RI) team at RBC GAM. In this role, he assists investment teams with the integration of ESG considerations into the investment process, conducts analysis, and executes proxy voting activities for RBC GAM funds and client accounts. Prior to joining the team in 2022, Alan held a range of roles within RBC GAM and RBC Wealth Management globally, first joining RBC in 2015. Previous roles focused on portfolio management and wealth planning. Alan began his career in the investment industry in 2012.

Andrew Hakes: MGA, Munk School of Global Affairs & Public Policy, University of Toronto; B.A. (Hons), University of Western Ontario
Andrew is an Analyst on the Responsible Investment (RI) team at RBC GAM. In this role, he assists investment teams with the integration of ESG considerations into the investment process, conducts analysis, and executes proxy voting activities for RBC GAM funds and client accounts. Prior to joining the firm in 2022, Andrew worked for a research organization focused on sustainable finance and as an analyst at a consultancy firm focused on corporate sustainability.

Winnie Hu: MBA, John Molson School of Business, Concordia University; B.A , McGill University
Winnie is an Analyst with the Responsible Investment (RI) team at RBC GAM, assisting investment teams with their ESG integration processes, proxy voting, and engagement efforts. She previously held the role of an Analyst within RBC GAM’s Global Fixed Income & Currencies team where she researched and traded interest rates products for global developed markets. Winnie held a range of roles within RBC GAM, first joining RBC in 2019.

Data & Analysis

Mark Tang: CFA, MBA, Western University; B.Com., University of Toronto
Mark is Manager on the Responsible Investment (RI) team for RBC Global Asset Management (RBC GAM) and leads on data and analysis. Mark provides support for the RI team for: data strategy, data implementation, product management, and quantitative research. Mark joined RBC Wealth Management as part of the Wealth Management Generalist Program in 2019 and has completed short duration rotations in business technology, and quantitative investments. Prior to working at RBC WM, Mark held various accounting, investment performance & operations roles at numerous financial institutions.

Fixed Income

My-Linh Ngo: Level 4 Certificate in Investment Management Certificate (IMC), CFA UK; MProf., Leadership for Sustainable Development, Middlesex University/Forum for the Future; M.Sc., and B.Sc., (Hons) Environmental Sciences, University of East Anglia
My-Linh is Senior Director & Impact-Aligned Strategist in the Responsible Investment (RI) team for RBC GAM, with lead responsibility for ESG integration and stewardship across the firm’s global fixed income assets, including BlueBay fixed income. She is also a sustainability strategist for the impact-aligned bond strategy managed on the BlueBay fixed income investment platform. My-Linh represents RBC GAM and RBC BlueBay externally in a range of committees and working groups focused on driving RI best practice in the fixed income asset class. She has over two decades of experience working in the RI industry, joining BlueBay Asset Management (which is now part of RBC GAM) in 2014. Prior to this, My-Linh was at Schroders Investment Management Ltd as an ESG Analyst, and at Henderson Global Investors as an Associate Director – SRI Research.

Lucy Byrne: M.Sc., Environmental Technology and M.Sci., in Environmental Geoscience, Imperial College London
Lucy is a Senior Manager in the Responsible Investment (RI) team for RBC GAM, with a focus on ESG incorporation across the firm’s global fixed income assets, including BlueBay fixed income. She joined BlueBay Asset Management (which is now part of RBC GAM) in July 2018 as an ESG Analyst and was made a Senior ESG Analyst in January 2020. Lucy is an experienced environmental and sustainability consultant, and prior to BlueBay, was an Assistant Manager, Sustainability Services at KPMG where she worked with financial institutions and companies across a range of sectors and geographies, on their sustainability strategies and reporting and assurance activities.

Ian Clarke: Business and Climate Change certification, University of Cambridge (CISL); Chartered Management Accountant (CIMA); BA., (Hons) Accounting and Finance, De Montfort University
Ian is a Senior Analyst in the Responsible Investment (RI) team for RBC GAM, involved in ESG integration and stewardship across the firm’s global fixed income assets, and a focus on climate. He is an experienced financial services management consultant, advising on strategy and transformation, and since 2018, has been specialising in sustainability, ESG and climate change. During his eight years at Baringa Partners, most recently as a Senior Manager, Ian worked with clients across banking, asset management and private equity industries. Prior to this, Ian spent 10 years as an accountant for various international financial services companies.

Younes Hassar: MA, Business Management (Major in Finance) and B.Sc., Economics, SKEMA Business School (Paris)
Younes is a Senior Analyst in the Responsible Investment (RI) team for RBC GAM, involved in ESG integration and stewardship across the firm’s global fixed income assets, with a focus on macro/sovereign ESG. With over 14 years’ experience in the financial services industry, Younes has held various in-house, as well consultancy, roles which have ranged from product management to macro analysis, to ESG and sustainability-oriented ones within the last decade at BNP Paribas, HSBC, Aviva Investors, and most recently at Federated Hermes.

Emir Beganovic: MBA, Kellogg School of Management – Northwestern University; CFA Charterholder; BA, Economics and German Studies, Macalester College
Emir is an Analyst in the Responsible Investment (RI) team for RBC GAM. Based in the US, Emir is involved in ESG integration and stewardship across the firm’s global fixed income assets, with a particular focus on strategies managed in North America. Emir joined RBC GAM (US) in 2022. Prior to that, he led the ESG program for the asset management division of a Fortune 500 insurance company where he also gained experience as an investment product manager with a focus on fixed income strategies. Emir has previously been employed at RBC, having started his career with RBC Wealth Management, working in various roles from 2010 to 2016.

Vibha Lad: Certificate in ESG Investing and Level 4 Certificate in Investment Management Certificate (IMC), CFA UK; CIMA Diploma MA; B.Sc., (Hons) Economics, Brunel University
Vibha is an Analyst in the Responsible Investment (RI) team for RBC GAM. She held Fund Accountant roles at BlueBay Asset Management (which is now part of RBC GAM) from 2015. During 2022, she moved to specialise in ESG investing as an ESG Investment Operations Manager, supporting ESG data infrastructure and operational aspects of the BlueBay fixed income investment platform. During 2023 Vibha has been transitioning to an RI analyst role, supporting ESG integration and stewardship across RBC GAM’s global fixed income assets. Vibha began her career in the investment industry in 2014 and held roles at PwC and Schroders - Cazenove Capital Wealth Management.

Active stewardship

As stewards of our clients’ assets, we encourage the issuers in which we invest to act in alignment with the best interests of our clients.
We address topics such as board structure, executive compensation, gender diversity, and climate change with issuers and regulatory bodies, where material. We do this by employing the following three methods: proxy voting, engagement, and participating in collaborative initiatives.

Proxy Voting

Voting responsibly at the meetings of issuers in our portfolios is an important way we act in the best interest of our clients. We make each voting decision independently, in accordance with our Proxy Voting Guidelines (rbcgam.com). These custom guidelines provide an overview of the principles we support and how we will generally vote on particular issues. They are updated yearly to reflect our views on emerging trends in corporate governance and responsible investment. Our guidelines are applied for companies based in Canada, the United States, the United Kingdom, Ireland, Australia, and New Zealand. As stated in our guidelines, in all other markets, RBC GAM uses the local proxy voting policies of Institutional Shareholder Services (ISS).

Engagement

We believe that issuers that manage their material ESG risks and opportunities effectively are more likely to outperform on a risk-adjusted basis over the long term. Our approach to engagement reflects this belief, as we engage in dialogue with issuers over time and participate in initiatives that increase transparency and foster fair and efficient markets for the benefit of all investors and clients globally.

Our investment teams and RI team may meet with the issuers in which we invest on an ongoing basis. The specific ESG factors we engage on differ based on sector, asset class, and geography, as engagement cases are prioritized based on the materiality of the ESG issue to the specific investment. Teams may also prioritize their engagement efforts based on the size of the investment and/or the level of ESG risk within the portfolio. As a firm, we recognize that corporate governance and climate change are of particular relevance to us. We seek to understand each issuer individually and through the lens of local norms and the laws and regulations of the market(s) in which it operates.

Typically, the objectives of our ESG-related engagements include:

▪ Information gathering on material ESG risks and opportunities and the steps the issuer is taking to address them;
▪ Seeking better public disclosure of material ESG risks and opportunities and the steps the issuer is taking to address them;
▪ Encouraging more effective management of material ESG factors, when we believe they may impact the value of the investment; and
▪ Where an issuer is lagging its peers on a material ESG issue, requesting a commitment for change, monitoring any changes, and encouraging continued improvements that are expected to positively impact the long-term value of the investment.

Collaborative initiatives

We participate in initiatives that work to increase transparency, protect investors, and foster fair and efficient capital markets. We recognize that advocating for regulatory and legal reform can be more effective when market participants work together. Where interests are aligned, collaboration with like-minded investors can give us greater influence on issues specific to our investments and on broader, market-wide considerations. In either case, we work to encourage changes that are in the best interests of our clients.

30% Club Canadian Investor Group
RBC GAM is a signatory to the 30% Club Canadian Investor Group, a coalition of Canada’s largest institutional investors, which calls on publicly-traded companies to take prompt and considered action to achieve and exceed the 30% gender diversity target and to enhance the presence of other underrepresented groups on their boards and at the executive management level. The coalition has instigated numerous engagements, for which RBC GAM may engage, provide inputs, and/or provide feedback.

Alternative Investment Management Association
We are a member of the Alternative Investment Manager Association (AIMA), the global representative of the alternative investment industry. AIMA draws upon the expertise and diversity of its membership to provide leadership in industry initiatives such as advocacy, policy and regulatory engagement, educational programs and sound practice guides.

Canadian Coalition for Good Governance
RBC GAM is a founding member of the Canadian Coalition for Good Governance (CCGG), which promotes good governance practices in Canadian public companies and works to improve the regulatory environment to best align the interests of boards and management with their shareholders. Members of RBC GAM’s RI team serve on the Public Policy and Environmental & Social committees.

CDP
We are signatories to the CDP, formerly known as the Carbon Disclosure Project. The CDP runs the global disclosure system that enables entities to measure and manage their environmental impacts and strives to advance environmental disclosure.

Climate Action 100+
We are signatories to the Climate Action 100+, an investor-led initiative that focuses on active engagement with the world’s largest publicly traded and systemically important carbon emitters, or companies with significant opportunity to drive the transition to a low-carbon economy.

Climate Engagement Canada
We are a founding participant of Climate Engagement Canada (CEC), is a finance-led initiative that drives dialogue between the financial community and corporate issuers to promote a just transition to a net-zero economy. This is a national engagement program in Canada, akin to Climate Action 100+. A member of RBC GAM’s RI team is Chair of the Technical Steering Committee.

Council of Institutional Investors
RBC GAM is a member of the Council of Institutional Investors (CII). The CII aims to promote effective corporate governance, strong shareowner rights and vibrant, transparent and fair capital markets.

Emerging Markets Investor Alliance
We are a member of the Emerging Markets Investor Alliance EMIA), which aims to enable institutional emerging market investors to support good governance, promote sustainable development, and improve investment performance in the governments and companies in which they invest.

European Leveraged Finance Association
One of our investment teams is a member of the European Leveraged Finance Association. The ELFA aims to seek a more transparent, efficient, and resilient leveraged finance market.

Farm Animal Investment Risk & Return
We are a member of the Farm Animal Investment Risk & Return (FAIRR). FAIRR is a collaborative investor network that raises awareness of the ESG risks and opportunities brought about by intensive livestock production.

FX Global Code
RBC GAM is signatory to the FX Global Code July 2021, a set of global principles of good practice in the foreign exchange market, developed to provide a common set of guidelines to promote the integrity and effective functioning of the wholesale foreign exchange market. It was developed by a partnership between central banks and Market Participants from 20 jurisdictions around the globe. The Global Foreign Exchange Committee promotes, maintains and updates the Code regularly. RBC GAM’s Head of Global Fixed Income & Currencies is a member of the Canadian FX Committee.

Global Impact Investing Network
RBC GAM is a member of the Global Impact Investing Network (GIIN). The GIIN is the global champion of impact investing, dedicated to increasing the scale and effectiveness of impact investing around the world.

Green Bond Transparency Platform (GBTP)
One of our investment teams is a supporter of the Inter-American Development Bank (IDB)’s Green Bond Transparency Platform (GBTP), an innovative open access digital tool that brings greater transparency to the Latin American and Caribbean green bond market and aims to provide a benchmark for best practice disclosure and support to all market actors. We provided feedback and input into the platform.

International Corporate Governance Network
RBC GAM is a member of the International Corporate Governance Network (ICGN). The ICGN aims to promote effective standards of corporate governance and investor stewardship to advance efficient markets and sustainable economies worldwide. A member of RBC GAM’s RI team is on the ICGN’s Global Governance Committee.

IFRS Sustainability Alliance
We are a member of the IFRS Sustainability Alliance, a global membership program for sustainability standards, integrated reporting, and integrated thinking. Upon the Value Reporting Foundation’s consolidation into the IFRS Foundation, the IFRS Foundation’s International Sustainability Standards Board (ISSB) assumed responsibility for the SASB Standards. The ISSB has committed to build on the industry-based SASB Standards and leverage SASB’s industry-based approach to standards development. The ISSB encourages preparers and investors to continue to use SASB Standards. A member of RBC GAM’s RI team is on the Investor Advisory Group.

Investor Stewardship Group
RBC GAM is a founding member of the Investor Stewardship Group (ISG). The ISG is a collective of institutional investors brought together to establish a framework of basic standards of investment stewardship for institutional investors and corporate governance principles for U.S. listed companies. A member of RBC GAM’s RI team is on the ISG board.

Investment Association
We are a member of the Investment Association. The Investment Association is the United Kingdom’s membership association for investment managers. One of our investment teams participates on the Fixed Income Stewardship Working Group of the IA.

Investors Policy Dialogue on Deforestation (IPDD)
RBC GAM is a supporting investor of the IPDD in Brazil, which is co-chaired by the BlueBay Fixed Income Investment platform. The IPDD initiative aims to coordinate a public policy dialogue with authorities and monitor developments to assess exposure to financial risks arising from deforestation.

Japanese Stewardship Code
RBC GAM is a signatory to the Japanese Stewardship Code. The Code sets out the principles that institutional investors should adhere to in order to fulfill their stewardship responsibilities to clients, beneficiaries and investee companies.

Mission Investors Exchange
RBC GAM is a member of the Mission Investors Exchange, the leading impact investing network for foundations dedicated to deploying capital for social and environmental change.

Responsible Investment Association
RBC GAM is a sustaining member of the Responsible Investment Association (RIA). The RIA is Canada’s membership association for responsible investment. A member of RBC GAM’s RI team is the Vice-Chair of the RIA board.

Standards Board for Alternative Investments
We are a member of the Standards Board for Alternative Investments (SBAI). The SBAI aims to help institutional investors and alternative investment managers better understand how responsible investment can be applied in different alternative investment strategies, as well as the specific challenges and questions that arise in these contexts. A member of the RI team participates in the Responsible Investment Working Group, which aims to help institutional investors and alternative investment managers better understand how responsible investment can be applied in various alternative investment strategies.

UK Stewardship Code
RBC GAM is a signatory to the UK Stewardship Code 2020 (the Code). The code aims to enhance the quality of engagement between asset managers and companies to help improve long-term risk-adjusted returns to shareholders. RBC GAM’s 2022 Annual Stewardship Report met the expected standard of reporting of the Financial Reporting Council (FRC). RBC GAM’s 2023 Annual Stewardship Report is currently under review by the FRC.*

* In 2023, RBC GAM consolidated the activities of two regulated legal entities in the United Kingdom (UK), RBC GAM-UK and BlueBay Asset Management LLP (BlueBay), into RBC GAM-UK. BlueBay has not filed a separate 2022 Annual Stewardship Report. BlueBay’s stewardship activities are incorporated throughout RBC GAM’s 2022 Annual Stewardship Report.

UN Principles for Responsible Investment
RBC GAM is a signatory to the UN Principles for Responsible Investment (PRI)*. The PRI is a global network for investors committed to incorporating ESG considerations into their investment practices and ownership policies. We are committed to putting the PRI’s six Principles of Responsible Investment into practice and believe that they are aligned with our existing approach to responsible investment. A member of RBC GAM’s Responsible Investment team sits on the Policy Committee.

We are also a signatory to the PRI Statement on ESG in Credit Ratings, which encourages credit rating agencies to proactively take ESG factors into consideration for relevant issuers.

*In 2023, RBC GAM consolidated the activities of two regulated legal entities in the United Kingdom (UK), RBC GAM-UK and BlueBay Asset Management LLP (BlueBay), into RBC GAM-UK. BlueBay was previously a separate signatory to the UN PRI. RBC GAM’s most recent PRI Transparency Report is inclusive of BlueBay.

US SIF - The Forum for Sustainable and Responsible Investment
RBC GAM is an institutional member of US SIF. US SIF is the leading voice advancing sustainable, responsible and impact investing across all asset classes. Its mission is to rapidly shift investment practices toward sustainability, focusing on long-term investment and the generation of positive social and environmental impacts.

SDR Labelling: Not eligible to use label