ESG Integration Framework • Implementation of the ESG exclusion policies (controversial 03.10.2 Annual review weapons and coal) Discussion of ESG-related topics is an inherent part of regular • Compliance to the corresponding Sensitive Business Guideline annual asset manager reviews. Since 2014, ESG-specific annual (for non-listed assets) and/or consideration of the ESG reviews with asset managers are conducted in addition to general Integration Framework (for listed assets) for any transaction in review meetings. The purpose of these reviews is to assess the asset a sensitive business area managers’ ESG policies, their application and related processes. • Immediately disclose and report any ESG-related issues, conflicts, concerns and breaches to AIM • Provide ESG-related information for external reporting to AIM upon request • Report on ESG-related topics to AIM within the annual asset manager review Where no policy is in place, a commitment must be made to develop one over a pre-defined period of time. AIM monitors compliance with these requirements and reports on these in the Group Sustainability Report. Minimum Standards for ESG Policies An asset manager’s ESG Policy is defined as a written document which shall fulfil the following criteria: • State the ESG-specific principles according to which the asset manager acts and decides • Describe the applied approaches of ESG integration (such as investment research, exclusions, best-in-class approaches, monitoring, reporting, control mechanisms to ensure the proper implementation of the integration process etc.), • Outline the available and employed resources, • list annual ESG specific-targets, and • is an official company document approved by responsible board or committee. An asset manager who is a signatory of the UN-backed Principles for Responsible Investment (PRI) will also need to have at least a score of a “B” in the latest PRI assessment and/or have an an adequate ESG integration approach. 36