Rathbones Group PLC

#### Environmental

##### Global Standard on Responsible Climate Lobbying

The standard was set up to strengthen the commitment of investors and companies to responsible lobbying on climate change – lobbying to achieve goals that are consistent with the Paris Agreement. The standard was set up by the Church of England Pensions Board, with the support of a number of investor organisations: the Asia Investor Group on Climate Change (AIGCC), Ceres, the Interfaith Center on Corporate Responsibility (ICCR), the Investor Group on Climate Change (IGCC), the Institutional Investors Group on Climate Change (IIGCC), the Principles for Responsible Investment (PRI) and SHARE.

We joined others in signing letters to 23 European Climate Action 100+ target companies – large corporate emitters of greenhouse gases – that haven't yet published or committed to publishing a climate lobbying disclosure. The letters don't threaten escalation. They are intended, rather, as a positive reinforcement of investor interest in Indicator Seven of the Climate Action 100+ benchmark: climate policy engagement. Investors hope they will steer the recipient companies towards better practice. We were expecting an update by the end of 2022.

Our engagement policy outlines our approach to monitoring existing engagements and determining our engagement priorities. We regularly track and report the progress of existing engagement activity to our engagement and responsible investment committees. We show a scorecard for progress made during 2023 at the end of this document. The engagement and responsible investment committees review and sign off proposed priorities for engagement activity each year. The decision framework takes account of the following factors: — Exposure: we're more likely to engage directly where we hold a 'material' stake in the company. This is where we own more than 2.5% of a company's total shares in issue or where we hold the security widely across client portfolios. We're also more likely to engage where the company is on the list of investments recommended by our central investment committees. — Severity: we're more likely to engage on issues that: — present an immediate or severe threat to the best interests of our clients — could have a significant effect on our investments — involve pressing and severe ESG issues. — Location: we're more likely to engage directly with companies when we have a deeper understanding of the local legal framework. Companies with operations across many countries may be better suited to collaborative engagements. — Expertise: we're more likely to engage when we have deeper experience of a company or issue. We're cognisant that it's important to retain capacity to respond to new, emerging issues through engagement. While continuing to consider the long term, we must remain nimble. One example is responding to an accident relating to environmental pollution caused by a company. Another example could be taking part in one-off opportunities for targeted engagement that may arise from long-term collaborative engagement campaigns. Our prioritisation process applies to both wide-ranging engagement on a particular issue and involvement with particular companies.

The overarching responsibility for our RI activities sits with the Rathbones Group board. Within the governance structure supporting the board, our Responsible Investment Committee (RIC) provides oversight and guidance for our approach to RI. The RIC undertakes an annual review of this policy. [...] Our Engagement Committee provides oversight of our engagement activities, including responsibility for defining SMART goals where relevant, tracking progress against objectives, advising on an escalation approach, and acting as an end point for engagements. The Engagement Committee provides regular updates to the RIC.

Describe the process(es) your organization has in place to ensure that your engagement activities are consistent with your overall climate change strategy[…]It is essential that engagements be delivered in an effective manner. A procedure has been adopted whereby potential new ESG engagements are presented for review and approval by the responsible investment committee. As part of this process, every engagement must demonstrate compliance with this policy, but also state intended outcomes, setting 'precise and well informed objectives'. Progress against these objectives is tracked regularly. Further, we note that certain ESG issues are of a nature to involve systemic risks to multiple aspects of society. Therefore, we will develop detailed and specific engagement policies for these issues. The responsible investment policy has instructed the following specific engagement polices to be drafted and implemented — it is expected that more will be added over time:
— group climate change engagement policy
— group human rights engagement policy.