###### Engagement responsibilities
We believe the responsibility for ESG engagement should fall with those making the investment decisions: the analysts and portfolio managers. In our view, companies with strong ESG frameworks tend to operate more sustainably, carry less risk of stakeholder intervention and are more likely to build and sustain valuable brands and reputations. Thus, engagement on ESG is deeply embedded into our ordinary due diligence as part of our investment process. We have also found companies more likely to engage with the decision makers behind their large shareholdings, again putting us in a uniquely effective position for advocacy.
Equally important in the engagement and advocacy process is monitoring to ensure ongoing compliance and alignment. We do this through regular dialogue with senior management and other stakeholders as required. We seek a level of measurable accountability from the companies we invest in, allowing improvement over the duration of our holding period. [...] ###### Escalation policy
If our attempts at engagement are ignored or material issues remain unresolved, we will escalate any matters of concern beyond corporate senior management teams. This may include contact with the company's board of directors or relevant regulators, the use of proxy voting or collaboration with other shareholders. At all times, we reserve the right to divest our position in any investment that refuses to engage on ESG matters.