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European SRI Transparency Code Version 3:0

The European SRI Transparency Code (the Code) focuses on SRI funds distributed publicly in Europe

and has been designed to cover a range of assets classes, such as equity and fixed income.

All information pertaining to the European SRI Transparency Code can be found at the following

website: www.eurosif.org. The Code comes with a Guidance Manual for fund managers on how to best

use and respond to the Transparency Code. The present version of the Code has been approved by the

Board of Eurosif on October 3, 2012.

TWO KEY MOTIVATIONS UNDERPIN THIS CODE

1. The opportunity for retail SRI funds to clarify their SRI approach to investors and other stakeholders in an easily accessible and comparable format.

2. Proactively strengthen a self-regulation that contributes to the development and promotion of SRI funds by setting up a common framework for transparency best practices.

GUIDING PRINCIPLE

Signatories to the Code should be open, honest and disclose accurate, adequate and timely

information to enable stakeholders, in particular consumers, to understand the ESG1 policies and

practices of the fund.

COMMITMENTS FROM SIGNATORIES

The order and exact wording of the questions shall be respected;

Responses should be informative and clear, and the resources and methodologies deployed should be described with as much detail and precision as possible;

Funds should report data in the currency that they use for other reporting purposes;

Reasons preventing the fund from providing all or part of the information to a given question should be clearly stated and, in such a case, signatories should state when they will be able to answer the question;

Responses shall be updated at least on an annual basis and should have a precise publication date;

Responses to the Code should be easily accessible on the fund’s and/or fund manager’s website. In any case, signatories should make it clear where to find the information required by the Code;

Signatories are solely responsible for the answers to the questions, and should state this in their response.

1 ESG stands for Environmental, Social and Governance.

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To clarify these commitments, signatories should include at the beginning of the response document

the following two statements:

Statement of Commitment

Sustainable and Responsible Investing is an essential part of the strategic positioning and behaviour of

RobecoSAM AG. We have been involved in SRI since 1995 and welcome the European SRI Transparency

Code.

This is our eight statement of commitment and it covers the period 01.09.2017 to 31.08.2018. Our full

response to the European SRI Transparency Code can be accessed below and is available in the annual

report of the retail funds and on our website.

Compliance with the Transparency Code

RobecoSAM AG is committed to transparency and we believe that we are as transparent as possible

given the regulatory and competitive environments that exist in the countries in which we operate.

RobecoSAM meets the full recommendations of the European SRI Transparency Code.

August 2017

CODE CATEGORIES

Section 1 – Basic Details

The Fund Management Company

1a Provide the name of the fund management company managing the fund(s) to which this code apply.

Provide general information about The Fund Management Company managing the fund(s) to which

this code applies (e.g. name, address, website…).

RobecoSAM AG (formerly SAM Sustainable Asset Management AG) Josefstrasse 218, CH-8005 Zürich Web: www.robecosam.com Johannes Weisser Client Portfolio Manager RobecoSAM Email: johannes.weisser@robecosam.com Tel: +41 44 653 1047 Web: www.robecosam.com

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1b Describe the general approach of the fund management company with regards to how it takes

environmental, social and governance (ESG) criteria into consideration.

Is the fund management company approach towards ESG criteria aligned or inspired by its corporate

social responsibility approach? Yes/No. If yes, insert a link to the company’s CSR policy. If not, explain

why not.

Founded in 1995, RobecoSAM is an investment specialist focused exclusively on Sustainability Investing. Our mission is to drive sustainability thinking. We use financial markets as the most powerful transmission mechanism to promote sustainable business practices. With our exclusive focus on Sustainability Investing, we provide a unique and broad range of sustainability solutions for investors and corporates.

We are convinced that companies with sustainable business practices are more successful. Our vision is to set the standard in Sustainability Investing. As a thought leader, we contribute to this continuous development through our Sustainability Foresight.

As a reflection of its own commitment to advancing sustainable investment practices, RobecoSAM is a signatory of the PRI and, UN Global Compact, a member of Eurosif, Swiss Sustainable Finance (SSF), Carbon Disclosure Project (CDP), the Portfolio Decarbonization Coalition (PDC), the GIIN, the FNG as well as the Sustainability Accounting Standards Board (SASB) and partner of the “Swiss Climate Foundation”.

Please find below for an overview of RobecoSAM’s corporate responsibility achievements, cooperation’s and international affiliations: 2001: RobecoSAM becomes the first company in Switzerland to receive the Carbon Neutral(r)

status in 2001, and is awarded the CarbonNeutral(r) status each year since. 2002: RobecoSAM partners with the Association for Sustainable & Responsible Investment in

Asia (ASrIA) 2004: RobecoSAM a signatory to the transparency guidelines for sustainable retail funds issued

by the European Social Investment Forum (Eurosif) 2007: RobecoSAM becomes a signatory of the Principles for Responsible Investments (PRI). In

July 2017, RobecoSAM was again awarded an A+ score in all assessed modules by the UN PRI for their overarching approach to Sustainability Investing.

2009: RobecoSAM becomes a member of the Investor Network for Climate Risk, the Ceres

Coalition as well as the Global Impact Investing Network (GIIN). 2010: RobecoSAM signs and endorses the CEO Water Mandate, which is an initiative of the UN

Global Compact. 2011: RobecoSAM becomes a partner of co2-monitor – a tool which enables the users to

discover their personal CO2 emissions and find out how to reduced it.

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RobecoSAM becomes member of the Global Initiative for Sustainability Ratings (GISR), a

public benefit organization aimed at making financial markets agents of, rather than impediments to, achieving the Sustainable Development Goals and broader global sustainability agenda

2013: RobecoSAM establishes a collaboration with (CDP): CDP is the provider of the only global

environmental disclosure system and the producer of the annual Climate Disclosure and Climate Performance Leadership Indexes (CDLI & CPLI). In the annual RobecoSAM Corporate Sustainability Assessment, RobecoSAM now asks public companies the same climate change questions as those developed over the past decade by CDP. This collaboration improves the comparability of sustainability data in the global market.

2015: RobecoSAM became a signatory of the Portfolio Decarbonization Coalition (PDC), a

multi-stakeholder initiative that will drive global greenhouse gas (GHG) emission reductions by mobilizing a critical mass of institutional investors committed to gradually decarbonizing their portfolios.

RobecoSAM became a signatory of the Global Investor Statement on Climate Change RobecoSAM sponsors the "Sustainable Games: The Business Model Challenge”.

Initiated by Cornerstone Capital Group and supported by UN PRME and the Clinton Global Initiative, students across the globe are asked to present a business model of the future. This business model must be aligned with a more regenerative form of capitalism and therefore should address environmental, social and governance challenges and opportunities.

RobecoSAM supports and collaborates with the Global Child Forum Starting in 2015, RobecoSAM and the Global Reporting Initiative (GRI) work together on

research and methodology. GRI and RobecoSAM have collaborated on research pieces that identify and report on material issues in certain industries. RobecoSAM has, where appropriate, aligned definitions and indicators to those present in GRI’s G4 framework and the new Standards. Finally, RobecoSAM and GRI collaborate to ensure that the reporting burden for companies can be reduced while aligning sustainability metrics to make them more consistent and relevant for the investment community.

Publications include “Defining Materiality: What Matters to Reporters and Investors”

and “Defining What Matters: Do companies and investors agree on what is material?”, they were published in 2015 respectively 2016.

2016 RobecoSAM is part of the Swiss team of UN EP Inquiry to develop the “Proposals

towards a Sustainable Financial System in Switzerland”. In February 2016, the Federal Council established principles for a consistent Swiss policy in this area. These principles have also been integrated in the Federal Council's report on the strategic thrusts of the financial market policy of October 2016. Furthermore, the competent federal authorities were actively involved in the corresponding international bodies, e.g. the G20 Green Finance Study Group (GFSG).

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RobecoSAM signs the PRI initiative “Global Statement on Investor Obligations and Duties”. A Call on international and supranational policymakers to clarify investors’ obligations and duties, in particular, in relation to the integration of ESG issues into investment practice.

2017: RobecoSAM becomes a supporter of the Task Force on Climate-Related Financial

Disclosures. In signing this statement, RobecoSAM affirms its commitment to support the voluntary recommendations of the industry-led Financial Stability Board (FSB) Task Force on Climate-related Financial Disclosures (TCFD). These disclosures are an important step forward in enabling market forces to drive efficient allocation of capital and support a smooth transition to a low-carbon economy.

Has the fund management company signed the Principles for Responsible Investment? If yes, please

insert the link to the answer to the PRI questionnaire. If not, explain why not.

RobecoSAM becomes a signatory of the Principles for Responsible Investments (PRI). In July 2017, RobecoSAM was again awarded an A+ score in all assessed modules by the UN PRI for their overarching approach to Sustainability Investing. RobecoSAM’s responses to the last PRI Reporting and Assessment survey can be requested via com@robecosam.com

Is the fund Manager a signatory or a member of other international and/or national initiatives

supporting SRI practices? Please answer if you deem this information to be useful.

Please refer to our response above on page 3, regarding RobecoSAM’s membership of international initiatives supporting SRI practice. In addition, we are involved in a number of academic collaborations in which we share our sustainability data with partner universities, business schools and research institutions, such as Swiss Federal Institute of Technology (ETH), Erasmus University and WWF UK, and support them in conducting empirical research on the linkages between sustainability performance and financial performance. Finally, we participate in a number of industry forums (such as UNPRI, Ceres, and Forum Nachaltige Geldanlage (FNG)) and thought-leadership initiatives in which we seek to advance key sustainability topics such as water footprint and education.

In 2004, RobecoSAM signed up to the transparency guidelines for sustainable retail funds issued by the European Social Investment Forum (Eurosif).

Has the fund management company established an ESG engagement policy? If yes, describe the policy

by outlining its objectives and its methodology and/or, if it is public, insert a link to the policy. If not,

explain why not.

RobecoSAM has two engagement approaches - through Robeco's Governance & Active Ownership (GAO) team (formerly part of RobecoSAM) as well as through its Corporate Sustainability Assessment (CSA).

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GAO Engagement

Robeco's Governance & Active Ownership team provides engagement and voting services for Robeco and RobecoSAM's funds and for our institutional investor clients. The team is comprised of seasoned professionals who have been encouraging companies in our investment portfolios to implement good corporate governance and responsible policies since 2005. In 2016, we engaged with 188 companies on 210 engagement cases. For full details on the 2016 engagement season can be found at:

https://www.robeco.com/docm/docu-20170321-robeco-active-ownership-report-2016.pdf

For further details, please refer to the Robeco Engagement Policy hyperlink:

https://www.robeco.com/docm/docu-robeco-engagement-policy.pdf

CSA Engagement

The CSA serves as a direct corporate engagement platform with over 900 of the world's largest corporations. Each year, RobecoSAM invites over 3,900 companies to participate in the CSA. In 2017, 942 companies completed the online questionnaire, covering a wide range of Economic, Environmental and Social topics. All participating companies are provided a Company Benchmarking Scorecard, that highlights their absolute performance as well as their relative performance to their peers. In 2016, we entered into a structured dialogue with more than 250 companies interested in improving their performance and provide them with a more in depth benchmarking report that outlines sustainability best practice approaches and provides more granularity on their relative strengths and weaknesses.

More information on RobecoSAM's Corporate Sustainability Assessment can be found here:

http://www.robecosam.com/csa

Has the fund management company established a voting policy? If yes, describe the policy by outlining its objectives and its methodology and/or, if it is public, insert a link to the policy. If not, explain why not.

Voting Rights

Robeco's Governance & Active Ownership team provides engagement and voting services for Robeco and RobecoSAM's funds and for our institutional investor clients. Robeco’s voting policy is principle-based as it relies on the internationally accepted set of principles of the International Corporate Governance Network (ICGN). This means that instead of following formula-based instructions to votes, careful analysis of proposals is carried out in order to take into consideration local regulations, corporate-governance codes of conduct, and common practice in different markets and sectors. The policy is reviewed every year to assess whether it is up to date with best

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practice. Based on this assessment it is decided whether significant changes should be made to the

policy. The most recent significant changes made to Robeco’s voting policy took place in 2014 following the revision of the ICGN Global Governance Principles.

Robeco’s voting policy is implemented through the custom voting policy that we have developed with our proxy voting service provider Glass Lewis. Every year we carry out a review and due diligence meet with our Proxy Voting Advisor and provider of the electronic voting platform to evaluate the voting process and the voting results. This evaluation is based on technical and infrastructure aspects of the voting process as well as on the content of the research and advisory services provided by them. We evaluate, for example, what the reasons are for distinctions between the vote recommendations of Glass Lewis and our final vote decisions. This way we try to identify the systematic aspects of Glass Lewis’s approach which are not in line with our Proxy voting policy. Furthermore, we aim for improvements in the cooperation with Glass Lewis which should lead to ongoing improvement of quality standards in the voting process.

Transparency is a key element of RobecoSAM’s corporate governance policy. We present our voting decisions shortly after the annual general meeting took place.

http://www.robecosam.com/en/professionals/strategies-services/governance-active-ownership/voting-reports.jsp

Highlights of the 2017 voting season can be found at:

https://www.robeco.com/docm/docu-highlights-voting-season.pdf

Describe how the fund management company or the group contributes to the promotion and the

development of SRI.

Promoting Sustainability Investing RobecoSAM also hosts the annual RobecoSAM Forum, bringing together institutional investors, asset managers and company stakeholders with the goal of analysing key sustainability trends shaping industries and financial markets. By connecting key decision-makers across the financial industry, the RobecoSAM Forum serves as a platform for establishing a global community of thought leaders and practitioners of sustainability investing. In addition, RobecoSAM is actively involved with over 10 other sustainability institutions and organizations.These institutional include the following:, Global Real Estate Sustainability Benchmark (GRESB), CDP, International Corporate Governance Network (ICGN), Investor Network on Climate Risk (INCR)/CERES, United Nations Environment Programme Financ Initiative (UNEP FI), United Nations Global Compact (UNGC), United Nations Principles for Responsible Investment, Global Reporting Initiative, ASRIA, International Integrated Reporting Committee (IIRC), and Sustainability Accounting Board Standards (SASB). In our view, the first step to being a responsible and active owner is to send companies a strong signal that we, as investors, are interested in how they manage sustainability issues. Our questionnaire used for the RobecoSAM Corporate Sustainability Assessment acts as a tool to encourage improved disclosure on key sustainability issues of interest to long-term investors and

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offers companies a blueprint of industry best practices. Moreover, the Dow Jones Sustainability Indices (DJSI), which is based on the results of RobecoSAM’s annual assessment, offers investors an indirect engagement platform to have a collective impact on companies through all our licensees. One of the merits of indirect engagement is that it expands the scope of our efforts. In the first phase of our Corporate Sustainability Assessment process, our invitations to the RobecoSAM assessment reach 3900+ companies every year. Over 900 companies participate actively in the assessment. Subsequently, we enter into structured one-on-one dialogues with over 200 companies that have demonstrated an interest in improving their sustainability performance. Discussions with management are based on a company-specific benchmarking report that compares the company’s performance with industry best practices on 120+ criteria. Finally, we engage with companies on an ad hoc basis if they appear to have been involved in controversial business activities or in breach of international norms and standards. Through RobecoSAM's Corporate Sustainability Assessment, companies are challenged on leading and under-reported sustainability topics - driving increased public disclosure over time and greater transparency for investors and other stakeholders. The RobecoSAM Corporate Sustainability Assessment process can therefore be seen as a combination of indirect engagement at the systemic level and direct engagement activities through active dialogues with companies which aim to improve specific aspects of corporate behaviour. RobecoSAM publishes the percentile rankings of all companies assessed down to the criterion level on the Bloomberg Professional platform. This information is available at no additional to cost to anyone with access to Bloomberg Professional and is intended to provide the broader investment community with RobecoSAM's research.

1c Describe/List your SRI products and the specific resources allocated to your SRI activities.

Briefly describe the SRI fund range (number, assets under management, strategies, ...)

Describe/Detail the resources allocated by the fund management company (organization, ESG research

internal/external, dedicated portfolio management team, …) and indicate where this information is

available.

Sustainability Solutions The firm’s offering comprises asset management and indexes. Its asset management capabilities include a broad range of regional and global equity, impact investing, and theme-based strategies in the areas of Water, Smart Energy, Smart Materials, Healthy Living and Agribusiness. In addition, it offers large institutional investors customized investment solutions and mandates that incorporate sustainability criteria, including optimized, active and unconstrained strategies. Every strategy is managed by a dedicated lead portfolio manager who has full decision making responsibility. Portfolio managers directly report to the Head of Investment Management, who is a member of RobecoSAM's Executive Committee.

Fund name Inception date Strategy AuM (EUR million) as of June 2017

Core Equity Funds

RobecoSAM Sustainable Global Equity Fund 03.05.2004 311

RobecoSAM Sustainable European Equities Fund 28.05.1991 698

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RobecoSAM Global Small Cap Equities Fund 30.03.2007 20

RobecoSAM Gender Equality Impact Equities 18.09.2015 14

RobecoSAM Global Child Impact Equities Fund 18.09.2015 15

Theme-based Equity Funds

RobecoSAM Sustainable Water Fund 28.09.2001 976

RobecoSAM Smart Energy Fund 23.09.2003 310

RobecoSAM Smart Materials Fund 02.10.2006 458

RobecoSAM Sustainable Healthy Living Fund 30.03.2007 260

RobecoSAM Sustainable Agribusiness Equities Fund 29.08.2008 87 In partnership with S&P Dow Jones Indices, RobecoSAM has developed and licenses the globally recognized Dow Jones Sustainability Indices (DJSI), launched in September of 1999. The DJSI family has since grown to include global, European, Eurozone, North American, US, Asia-Pacific Emerging Markets benchmarks and a Diversified index family. Sustainability Research RobecoSAM’s Sustainability research is generated internally, and is based on RobecoSAM’s annual Corporate Sustainability Assessment and the annual reports published by the companies covered by RobecoSAM’s Research. Over the last 18 years, RobecoSAM has identified and developed an extensive set of economic, environmental, and social assessment criteria in order to measure a company’s sustainability performance. These criteria are built into the questionnaire, which quantifies the sustainability performance of a company by assigning a corporate sustainability score based on predefined weights for each of the criteria. The data we collect is stored in RobecoSAM’s proprietary Sustainability Information Management System (SIMS), where it is converted into investment relevant insights.

Information used as inputs for the RobecoSAM Corporate Sustainability Assessment includes, among others, environmental, social and economic (raw) data provided by the companies, supporting documentation such as internal corporate strategies and policies, position papers, publicly available sustainability, environmental, or occupational health and safety reports. Fund holdings are published in RobecoSAM’s annual and semi-annual reports. These can be downloaded at: Funds | RobecoSAM Publications regarding the product capabilities such as prospectus, factsheets and fund brochures can be found under: http://www.robecosam.com/en/professionals/strategies-services/index.jsp

1d Describe the content, frequency and resources allocated/used by the fund management company

to inform investors about the ESG criteria taken into account.

The RobecoSAM Yearbook can be found in digital form and in form to download under: The Sustainability Yearbook | RobecoSAM RobecoSAM studies and white papers, Foresight, Insight and Flash can be found under: Sustainability insights | RobecoSAM

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The RobecoSAM Newsletter is on a subscription basis: Newsletter | RobecoSAM The Corporate Sustainability Assessment (CSA) Resource Center, containing information about the CSA Methodology, can be found here: RobecoSAM CSA Resource Center

The SRI Fund(s)

1e Provide the name of the fund(s) to which this Code applies and its (their) main characteristics

Describe the main characteristics of the fund(s): geographical focus, asset class, SRI strategy used (use

the classification provided by Eurosif/EFAMA).

As mentioned above, RobecoSAM exclusively focuses on sustainability investing. Therefore, all RobecoSAM strategies are managed according to the RobecoSAM sustainability principles. The RobecoSAM strategies are long-only equity products. Core strategies (regional): The core strategies invest in companies in the MSCI World, MSCI World Small Cap, and the MSCI Europe that have received a sustainability score (based on the RobecoSAM Sustainability Assessment), plus listed companies outside the respective index that are covered by RobecoSAM's sustainability theme strategies: RobecoSAM Sustainable Global Equities (LU0188782162) RobecoSAM Sustainable European Equities (LU0187077218) RobecoSAM Global Small Cap Equities (LU0280770172) RobecoSAM Global Gender Equality Impact Equities Fund (LU1277652514) RobecoSAM Global Child Impact Equities Fund (LU1277649130)

Theme strategies: Long-term sustainability related trends such as demographic change, resource scarcity, pollution, and climate change shape the competitive landscape in which companies operate. RobecoSAM's theme-based strategies invest in listed companies worldwide that anticipate and respond to challenges in the areas of Water, Smart Energy, Smart Materials, Healthy Living and Agribusiness: RobecoSAM Sustainable Water Fund (LU0133061175) RobecoSAM Smart Energy Fund (LU0175571735) RobecoSAM Smart Materials Fund (LU0175575991) RobecoSAM Sustainable Healthy Living Fund (LU0280770768) RobecoSAM Sustainable Agribusiness Equities Fund (LU0374106754)

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1f What is (are) this (these) fund(s) trying to achieve through taking into account ESG criteria?

For instance, financing a specific sector, reducing risks, support better CSR practices, develop new value

creation opportunities, other objectives.

Creating shareholder value through sustainability investing RobecoSAM’s overall corporate philosophy, product strategy and focus are based on its aim to provide a compelling range of sustainability products to its clients. By leveraging the comprehensive data collected by the RobecoSAM Corporate Sustainability Assessment, we are ideally positioned to identify companies leading their peers in terms of sustainability and, thus, shareholder value creation. RobecoSAM’s fundamental investment philosophy is based on the premise that overarching sustainability megatrends such as demographic change, resource scarcity, pollution, and climate change shape the competitive landscape in which companies operate and that the financial markets are the most powerful transmission mechanism to promote sustainable business practices. We believe that material, non-financial information fully integrated with traditional financial data gives investors an information edge. We believe that sustainability is all about a company’s capacity to prosper by anticipating and managing current and future economic, environmental and social opportunities and risks by focusing on quality, innovation and productivity to create a competitive advantage – and most importantly, long-term stakeholder value. We believe that these objectives focus companies on activities that positively affect their free cash flow, return on invested capital and weighted average cost of capital. RobecoSAM’s in-house empirical analysis demonstrates that sustainability investing delivers alpha to investors. Please consider our white paper "Alpha from Sustainability": http://www.robecosam.com/images/Alpha_from_Sustainability_06_2014.pdf

Section 2. Approach to ESG Evaluation of Companies

2a What fundamental principles underlie the ESG research methodology?

Describe the principles, standards or norms on which the ESG analysis is based for each of the

environmental, social/societal and governance dimensions. Include brief comments about how

stakeholders are consulted, as appropriate.

Economic, Environmental and Social Criteria Sustainability is the guiding principle of development “that meet the needs of the present without compromising the ability of future generations to meet their own needs.”2 Its central element is a future-oriented perspective that incorporates economic, environmental, and social considerations into business decisions. Factors such as good corporate governance practices, ethical behaviour,

2 Brundtland Commission, Our Common Future, 1987

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human capital management, environmental policies, and risk and crisis management are crucial contributors to the long-term success of a company. Similarly, Sustainability Investing is a long-term investment approach that integrates economic, environmental, and social criteria into the selection and retention of investments. Our conviction is that sustainability trends such as climate change, resource efficiency, or demographics have an impact on the environment in which companies compete, and their response to such challenges determines their ability to create shareholder value. The impact of these sustainability factors and trends on companies’ long-term business and financial performance is under-estimated and under-researched by investors, resulting in market inefficiencies, which RobecoSAM is well positioned to exploit. At the corporate level, sustainability is a future-oriented approach in which companies incorporate economic, environmental, and social considerations into their business decisions. Based on the global trend analysis, research identifies factors such as corporate governance practices, human capital management, environmental policies, and risk and crisis management that have a material impact on the long-term success of a company. Companies that are better at managing corporate sustainability risks than their peers are well-positioned to profit in the long run. By analysing the sustainability profile of companies and integrating it into traditional financial analysis, RobecoSAM gains additional insights that facilitate the selection of stocks offering the potential for attractive long-term returns, while investing in responsible companies. Media & Stakeholder Analysis As part of its annual Corporate Sustainability Assessment, RobecoSAM conducts an ongoing monitoring of companies that have been selected as members of the eligible investment universe for its funds, or as components of the Dow Jones Sustainability Indices. This monitoring process consists of a Media & Stakeholder Analysis, which is based on screening provided by RepRisk, a leading ESG research and business intelligence provider, and frequent interactions with key stakeholders such as NGOs and consumer organizations. Companies are monitored on an ongoing basis to verify their involvement in, and the management of critical environmental, economic and social crisis situations that can have a damaging effect on their reputation and core business. In addition, the consistency and quality of a company’s behaviour, response, and management of such situations is reviewed in line with its stated principles and policies. The Media & Stakeholder Analysis can lead to the downgrading of a company’s sustainability score, which may affect its overall fair valuation score. Examples of critical issues identified and reviewed through the monitoring process include:

Commercial practices; e.g. tax fraud, money laundering, antitrust, balance sheet fraud, and corruption cases.

Human rights abuses; e.g. cases involving discrimination, forced resettlements, child labour and discrimination of indigenous people.

Layoffs or workforce conflicts; e.g. extensive layoffs and strikes. Catastrophic events or accidents: e.g., fatalities, workplace safety issues, technical failures,

ecological disasters and product recalls.

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2b What internal and external resources are used to carry out this research?

Describe the general information used to carry out the ESG research: internal analysis, ESG rating

agencies, other external sources of information.

Information Source RobecoSAM’s Sustainability research is generated internally, and is based on RobecoSAM’s annual Corporate Sustainability Assessment and the annual reports published by the companies covered by RobecoSAM Research. Over the last 18 years, RobecoSAM has identified and developed an extensive set of economic, environmental, and social assessment criteria in order to measure a company’s sustainability performance. These criteria are built into the questionnaire, which quantifies the sustainability performance of a company by assigning a corporate sustainability score based on predefined weights for each of the criteria. The data we collect is stored in RobecoSAM’s proprietary Sustainability Information Management System (SIMS), where it is converted into investment relevant insights.

Information used as inputs for the RobecoSAM Corporate Sustainability Assessment includes, among others, environmental, social and economic (raw) data provided by the companies, supporting documentation such as internal corporate strategies and policies, position papers, publicly available sustainability, environmental, or occupational health and safety reports. Primary Research Each RobecoSAM analyst meets on average at least 50 companies per year. In addition to discussing financial performance issues, analysts also typically steer their conversations with company management towards long-term sustainability topics related to environmental and social issues in order to inform their view of a company’s risk-return profile. Our strong focus on primary research with respect to under-researched topics related to environmental, social and financial considerations enables RobecoSAM research to maintain an information advantage over mainstream investors who do not consider these factors in their investment process. External Sources of Information RobecoSAM’s Sustainability Application and Operations Team (SAOT) has subcontracted part of the sustainability assessments to Evalueserve in India. RobecoSAM has established a Service Level Agreement with Evaluserve, and the SAOT is responsible for the monitoring of the agreed service levels, and initiation of corrective actions by the service provider when relevant. Within Evalueserve, a limited pre-agreed team of analysts is working on the company assessments and DJSI information is treated confidential within the dedicated team. Further, the involved employees at Evalueserve are bound to confidentiality. For those companies that are not actively participating on the DJSI questionnaire, Evalueserve performs sustainability assessments by filling in the DJSI questionnaires based on publicly available information. In addition, RobecoSAM’s has subcontracted, through a cooperation agreement, part of the Media & Stakeholder Analysis research to RepRisk. Throughout the year, RobecoSAM monitors news coverage of companies in the universe on a daily basis using media stories compiled and pre-

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screened by RepRisk, a leading provider of media monitoring tools. News stories covered by the Media and Stakeholder Analysis (MSA) include a range of issues such as economic crime or corruption, fraud, illegal commercial practices, human rights issues, labor disputes, workplace safety, catastrophic accidents or environmental disasters. For actively managed strategies, RobecoSAM applies the following universe restrictions: weapons related military sales, firearms, controversial weapons and tobacco. For the screening of all investment universes and the application of additional respective filters, RobecoSAM works with the specialized research provider, Sustainalytics.

2c Which ESG analysis criteria are used?

Indicate what the main criteria for each of the environmental, social/societal and governance dimensions are. Specify if these criteria differ according to sectors, the geographical zones, the type of company, … If appropriate, provide an example. Sustainability Analysis Criteria Based on a global trend analysis, RobecoSAM has identified underlying economic, environmental and social megatrends such as aging infrastructure, access to capital, the scarcity of natural resources, and climate change, coupled with population growth, urbanization, and an aging population. Such trends represent opportunities and risks for companies to develop and market innovative products and services that address these long-term sustainability challenges. Those who can successfully anticipate to these trends are well-positioned to outperform in the long run. We use a “best in class” approach, as through our annual Corporate Sustainability Assessment we identify the most sustainable companies in each of the 60 industries. The sustainability scores, however, are integrated into the valuation model. Companies with a superior sustainability score will have a positive impact on their total valuation analysis, because we believe that more sustainable companies are better positioned to generate long term shareholder value. Sustainability laggards will have a negative impact on their overall valuation, as they are more likely to be underperformers in terms of their ability to maintain and grow earnings. Based on these trends, RobecoSAM has defined over 120 general and industry –specific criteria, across 60 different industries, which form the basis of the annual RobecoSAM Corporate Sustainability Assessment. All criteria are based on widely accepted standards, best practices and audit procedures as well as extensive input from industry specialists and consultants. RobecoSAM’s annual assessment is also used as the basis for the construction and annual review of the Dow Jones Sustainability Indices (DJSI). General criteria include standard management practices and performance measures applicable to all industries, such as corporate governance, environmental management and performance, human rights, supply chain management, risk and crisis management and labour practices. The industry specific criteria account for the majority of the assessment. Industry-specific criteria take into account the challenges and trends affecting specific industries. They reflect the economic, environmental and social forces driving the sustainability performance of a particular industry.

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The assessment is divided into three distinct sections, covering the economic, environmental and social dimensions. A selection of criteria used in the Assessment is outlined below.

RobecoSAM’s Industry-based analysis

Furthermore, our investment universe restricts firms with a significant exposure to damaging

activities, such as the production of tobacco or firearms.

Eligible universe – Universe Restrictions

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2d What is your ESG analysis and evaluation methodology (how the investment universe is built, rating

system, …)?

Describe the ESG evaluation/rating system and how it is built by explaining how the various ESG criteria

are articulated. If appropriate, provide an example.

RobecoSAM Sustainability Score RobecoSAM’s methodology is based on the application of economic, social and environmental criteria to assess the opportunities and risks deriving from these three dimensions. Over the last 18 years, RobecoSAM has identified an extensive set of criteria which are used to measure a company’s sustainability performance. These criteria are built into an extensive industry-specific annual questionnaire, the RobecoSAM’s Corporate Sustainability Assessment. It is used to obtain insights into each company’s response to a broad range of general and industry specific sustainability challenges. The information provided by a specific company is quantified based on predefined weights for each of the criteria, and results in a Sustainability Score – which is also used as a base for the construction of the Dow Jones Sustainability Indices. Additional sources of information used as an input for the sustainability assessment include supporting documentation such as sustainability reports, environmental reports, and health and safety measures provided by the companies, as well as personal contacts between the analysts and companies. In addition, analysts review media, press releases, articles, and stakeholder commentary written about a company over the past twelve months. This information is integrated into the sustainability analysis, and also serves as a basis for possible downgrading of a company’s sustainability score. Information provided in the questionnaire is verified. Verification includes crosschecking answers with documentation provided by the company, verifying a company’s track record and incidents and crisis management with media and stakeholder reports and, if necessary, direct interaction and clarification with the company. Industry-Specific Assessment RobecoSAM analyses the corporate sustainability information collected by focusing on the company’s position within its industry and chosen markets, its degree of preparedness for the opportunities and challenges arising from global sustainability trends, and the degree to which its business practices align management interests with those of the shareholders. Companies that are better at seizing opportunities and managing risks than their industry peers are well-positioned to profit in the long run. Thus, those companies that embrace corporate sustainability as a key source of competitive advantage and implement sustainable practices to mitigate risks and seize opportunities are more likely to receive a higher sustainability score compared to their peers. The score is then incorporated into the RobecoSAM Valuation Model, because RobecoSAM believes that management decisions regarding sustainability factors pertaining to the environment, social considerations and corporate governance have an impact on value drivers such as a company’s resource efficiency, workforce motivation, innovation potential, and reputation with stakeholders. The positive or negative impact of sustainable (or unsustainable) management decisions can then be measured in the company’s financials such as revenues, costs or reinvestment rates. Companies with a high sustainability score will enjoy a higher return on invested capital and/or a lower cost of capital, thus receiving a higher RobecoSAM Fair Value score.

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2e How frequently is the ESG evaluation reviewed?

Please briefly explain the methodology update process and who is involved. If appropriate, explain if

the methodology has changed in the past 12 months and the nature of the key changes.

RobecoSAM continuously makes enhancements to its research methodology in order to identify and interpret corporate sustainability information that has a material impact on long-term shareholder value creation. Such enhancements are aligned with our mission to leverage our understanding of sustainability issues in making better-informed investment decisions. Each SI research analyst is responsible for reviewing the sector-specific portion of the questionnaire for his or her area of coverage, and amending or including new questions for inclusion in the questionnaire, based on industry-specific sustainability trends, risks, and challenges affecting his or her specific research sector. We focus on ESG issues that are material to the companies' respective industries, long-term in nature, and that are under-researched in traditional financial analysis. As sustainability becomes more embedded in corporate practices, RobecoSAM regularly updates the questionnaire to capture new sustainability trends that are likely to have an impact on the companies' competitive landscape, and to continuously challenge companies to improve their policies and processes. The questionnaire for the annual RobecoSAM Corporate Sustainability Assessment is reviewed by RobecoSAM Research each year. Approximately 15-20% of the questions are yearly renewed and optimized. In the 2017 assessment, for instance, new questions on Policy Influence and Impact Measurement were introduced and increased focus was put on companies' assessment of risks in their supply chains. The section on Corporate Governance was extended to cover additional questions about board tenure and board industry experience. By doing so, we hope to raise awareness and eventually improve corporate performance in these areas. In addition to this, many other criteria were reviewed to ensure consistency, clarity and materiality of the questions asked. Other enhancements to our SI research process include a Materiality Analysis on the most relevant sustainability factors for the GICS industries that RobecoSAM analyses, and a new format for sharing companies’ Sustainability Profiles with other investment professional of the group. Because the Corporate Sustainability Assessment also forms the basis for the Dow Jones Sustainability Indices (DJSI), key criteria changes are published in the form of a Review Presentation, which can be downloaded. Annual Review DJSI RobecoSAM also presents and discusses major methodology through publications and webcasts. These can be found in the Corporate Sustainability Resource Center: CSA Resource Center Additionally, we publish an annual RobecoSAM Sustainability Yearbook, which includes some of the major changes to the RobecoSAM Corporate Sustainability Assessment. A copy of the yearbook can be found on our webpage: RobecoSAM Sustainability Yearbook

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To ensure quality and objectivity of the RobecoSAM Corporate Sustainability Assessment, an annual external review by Deloitte is completed. The review monitors and maintains the accuracy of the assessment procedures and results. The Assurance Statement can be downloaded as a PDF file at: Deloitte Assurance Report

Section 3. Fund Management Process

3a How do you take into account ESG criteria when defining the universe of eligible investments?

If appropriate, describe the eligibility threshold and the resulting level of selectivity.

Long-term Sustainability Drivers Based on its long-term experience and in-house sustainability expertise, RobecoSAM conducts a global trend analysis, which serves as the framework for defining sustainability drivers such as Demographics, Resource Scarcity, and Pollution. Investment Universe The investment universe for the RobecoSAM Core Strategies consists of all stocks in the MSCI World All Countries / MSCI World Small Cap / MSCI Europe that have received an above average sustainability score based on the RobecoSAM Corporate Sustainability Assessment, plus any companies with an exposure to one of the RobecoSAM Sustainability Themes: Water, Clean Energy, Materials, Healthy Living and Agribusiness. To demonstrate, we provide the selectivity criteria of the investment universe below for our Sustainable Global Equities strategy: The starting investment universe consists of approximately 3’000 stocks: It encompasses 1’700 companies of the MSCI World Index plus 1’300 companies outside the index that are covered by the RobecoSAM sustainability theme strategies. By broadening the Global Equity investable universe to include these small and mid-cap companies whose business activities directly address long term sustainability megatrends such as demographic change, resource scarcity, pollution and climate change, we can capture additional alpha opportunities. The starting universe is then screened for stocks above USD 1 billion market cap, resulting in an investment universe of approximately 2’200 companies. Universe Restrictions

An increasing number of investors recognize the value that they can derive from integrating

environmental, social and governance factors into their investment decisions. One of our strongest-

held beliefs is that companies that are able to add value for society will deliver superior returns to

their shareholders over the long term. The flip-side of this is that firms that are lagging behind in this

regard are likely to face headwinds from increasing regulation, public scrutiny, and reduced demand

from their customers over the long term.

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Besides this systematic integration of ESG factors in our investment process, we believe that some

products and business practices are detrimental to society in a way that makes them incompatible

with a sustainable investment strategy. With this in mind, at RobecoSAM we exclude from our

investment universe companies whose practices breach the principles of the United Nations Global

Compact and turn out to be unwilling or incapable of changing these practices even after active

engagement by our specialized team. In addition, our investment universe restricts firms with a

significant exposure to damaging activities, such as the production of tobacco or firearms.

Eligible universe – Universe Restrictions

For additional information on exclusion criteria thresholds, please refer to our above response in 2c. We believe that the resultant benefits to our clients are two-fold: it increases the likelihood of

them achieving the investment returns that they need, and enables them to make a positive

contribution to society through the deployment of their assets.

Environmental impact

The RobecoSAM Sustainable Global Equities strategy’s investment team uses a proprietary tool, the Impact Optimizer, to maximize the reduction of the portfolio environmental footprint, while minimizing the number of companies excluded from the investable universe. The Impact Optimizer was developed, in order to apply the environmental impact data in an efficient way in the universe screen and portfolio construction. The analytical reporting tool helps monitor the impact of the portfolio on the following four quantitative environmental impact indicators:

Greenhouse gas (GHG) emissions: measures direct GHG emissions generated by sources owned or con-trolled by the company (Scope 1 emissions) and indirect emissions associated with the generation of purchased electricity or heat (Scope 2 emissions).

Energy consumption: measures total energy directly consumed by the company as well as indirect energy consumed outside the organization.

Water use: measures company’s total water withdrawal, excluding water discharged with an equivalent quality level than the water extracted.

Waste generation: measures metric tons of dry waste generated by the company, consisting of by-products of the extraction or production process that can no longer be used for production or consumption and which the company intends to discard.

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The impact optimizer has three key goals: 1. Rank stocks according to their impact: The ranking can be used as a priority list for which stocks to exclude first from a given starting universe respectively which stocks to over-and underweight considering all four impact areas

2. Balance the four impact areas: The optimizer enables us to set an equalization effect across the four impact indicators. For the strategy, we start with a 25% weighting on the four indicators, and the optimizer helps maintain a balanced result as shifts within the portfolio occur as a result of turnover.

3. Ensure industry diversification: The optimizer will enable the user to balance between portfolio diversification and impact. A maximum threshold can be set on each GICS classification level 1-4 so that certain impact critical industries are not completely erased in a negative screening. The environmental impact objective within the portfolio is a 20% reduction of the portfolio- versus the index footprint across all four impact measures. To achieve this objective, companies in the investment universe are ranked according to their total footprint per million enterprise value on all four indicators (e.g., companies with large footprints on all indicators are likely to be removed first). We then balance the four impact areas by removing one company at a time, and using dynamic weights to prioritize removal of companies whose exclusion will ensure each impact measure is reduced equally in the final product (e.g., if the first company removed has very high GHG emissions, the next company removed is more likely to have very high exposure to one of the other three metrics). In order to ensure industry diversification, we limit the maximum removal of 2/3 of companies per GICS III sector. Our optimized approach balances the impact that a company has on the four different criteria. Through this approach, we create a starting universe with a superior impact profile. Of the approximately 2’200 companies in the starting universe, we screen out roughly 220 or 10%. The portfolio manager accordingly still has a broad set of investment opportunities, but one that ultimately leads to the creation of a low environmental impact portfolio Smart ESG After the impact optimizer has vetted out the worst environmental polluters from the starting universe, we apply our proprietary Smart ESG3 scores to the remaining investment universe. Based on extensive empirical studies, RobecoSAM has found that the leading sustainability companies (those with the highest Smart ESG scores) have outperformed the lagging sustainability companies over the time period for which proprietary sustainability data of RobecoSAM are available. Smart ESG is our new generation of ESG scores that build upon our existing sustainability data by eliminating known biases such as market cap, industry and regional biases. We are able to pinpoint which ESG indicators are the most financially relevant for different industries, sharpening our focus on financial materiality. This results in an unbiased, evidence-based ESG score – or Smart ESG – a powerful score that has an attractive risk-return profile and low correlation to other common investment factors. RobecoSAM’s Smart ESG data have thus a positive contribution to stock-picking.

3 For a full description of how we construct our smart ESG score and the empirical evidence of the relation between smart ESG and excess performance please refer to: Smart ESG integration, Factoring in Sustainability, September 2015, Bacon and Ossen, RobecoSAM.

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Smart ESG scores are based on the annual RobecoSAM Corporate Sustainability Assessment, RobecoSAM's proprietary methodology that was developed over 18 years and covers 60 sectors. It allows for a detailed assessment of underlying key economic, environmental, and social criteria which are linked to the business model and the financial value drivers of a company. RobecoSAM’s proprietary database contains sustainability information for over 3’800 listed companies. This assessment and database also enables the construction of the Dow Jones Sustainability Indices4. We select the top 2/3 of the highest ranking Smart ESG Score companies, approximately 1500, to complete our eligible investment universe for the portfolio. For the RobecoSAM Theme Strategies, the analysts define the universe by identifying companies that offer products and services addressing the sustainability challenges related to the respective theme. In order to be included in a thematic investment universe, a company should derive at least 20% of its current revenues and more than 50% of the anticipated future revenues from activities related to the respective investment strategy. At a portfolio level, at least 70% of the weighted company revenues should derive from activities related to the strategy. (At a portfolio level for the RobecoSAM Sustainable Water Strategy: min. 50% of the revenues.)

3b How do you take ESG criteria into account into the portfolio construction?

Describe how you link ESG selection with the financial analysis or with portfolio management. More

precisely, describe how the results of the analysis of each of the dimensions (E, S and G) are integrated

into the investment / divestment process. If applicable, state where you provide information on

divestments occurred in the past year on the basis of ESG criteria? If appropriate, explain how potential

ESG weightings are defined and describe your treatment of companies that are not subjected to an ESG

analysis.

The integration of sustainability criteria into the financial valuation of companies is the cornerstone of RobecoSAM’s research and investment philosophy. The firm is worldwide one of the market leaders in terms of integrating financial and sustainability insights into a structured investment process. Interpreting and Quantifying Sustainability Data RobecoSAM’s expertise lies in its ability to frame sustainability risks and opportunities, translate them into a proven corporate sustainability assessment methodology, and interpret the sustainability information we receive before incorporating it into our valuation model. The methodology focuses on material, under-researched issues that have an impact on companies’ ability to create shareholder value. The RobecoSAM Corporate Sustainability Assessment results in a sustainability score reflecting the companies’ sustainability performance against their industry peers. Companies that embrace corporate sustainability as a key source of competitive advantage and implement sustainable practices to mitigate risks and seize opportunities are more likely to receive a higher sustainability score.

4 RobecoSAM explains its proprietary methodology in the paper “Measuring Intangibles – RobecoSAM’s Corporate Sustainability Assessment” (http://www.robecosam.com/en/sustainability-insights/library/study.jsp)

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Integration RobecoSAM’s Valuation Model takes into account the company’s sustainability score as an input into the valuation analysis - the positive or negative impact of sustainable (or unsustainable) management decisions can then be measured in the company’s financials such as revenues, costs or reinvestment rates. Companies with a high sustainability score will enjoy a higher return on invested capital and/or a lower cost of capital, thus receiving a higher RobecoSAM Fair Value. Portfolio Construction The identified investment opportunities are individually weighted in order to constitute a well-diversified portfolio of investment holdings characterized by attractive fundamental valuation that considers the corporate sustainability profiles of the companies. Valuation is the main driver of long-term investment returns. By comparing the fair value with the current share price, the price-value discrepancy is determined, indicating the current attractiveness of a stock. In general, stocks with a high price-value discrepancy are bought. Stocks with a low price-value discrepancy are sold. The higher the price-value discrepancy of a stock, the higher weighting it receives in the portfolio. The stock selection process results in the best portfolio constituents by combining solid fundamental bottom-up stock analysis with market expectations. A media & stakeholder analysis (MSA) is conducted continuously throughout the year to identify companies in the investment universe that may have been involved in critical environmental, economic and social crisis situations that can have a damaging effect on their reputation and core business, and to evaluate their response and management of such situations. In addition, the consistency and quality of a company’s behavior, response, and management of such situations is reviewed vis-à-vis its stated principles and policies. Involvement cases can lead to a downgrading of the sustainability score, which will have an impact on the total valuation of the specific stock. Please find a listing below of the recent divestments over the last 12 months made based on ESG Criteria:

Effective June 19 2017, Fiat Chrysler Automobiles NV (MTAA: FCA) was removed from the Dow Jones Sustainability Indices following a Media & Stakeholder Analysis triggered by recent news events regarding their diesel emissions.

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3c Does (do) the fund(s) have a specific ESG engagement policy?

Please explain what you mean by engagement. Describe how you select the companies/themes for

engagement activities and the impact on the portfolio management of the fund(s). Who undertakes

engagement on behalf of the fund (internal and/or service providers)?

The RobecoSAM Corporate Sustainability Assessment as an Engagement Platform We consider the annual RobecoSAM Corporate Sustainability Assessment, which many companies use as a road map to implementing and improving their corporate sustainability practices, to be our principal platform for engagement. At a strategic level, RobecoSAM’s overarching engagement goal is to raise the bar for companies in terms of their sustainability performance and to send them a strong signal that long-term investors are interested in sustainability factors as a source of risks and opportunities. At the tactical level, we implement this goal by communicating explicitly the sustainability issues that we believe can have an impact on corporate financial performance of companies in a given sector through our industry-specific annual questionnaires (RobecoSAM Corporate Sustainability Assessment). Sustainability Benchmarking and Improvement Incentives The RobecoSAM Corporate Sustainability Assessment is a unique approach as it serves as a platform for ongoing engagement that is structured, rigorous, and has a broad reach. Each sustainability issue included in our assessment represents an engagement objective in the sense that we seek to encourage companies to improve their performance in that area. Each year our questionnaire reaches the 3900 largest companies, with over 900 companies actively participating in the assessment. Participating companies receive a benchmarking report that compares their sustainability performance to that of their industry peers, as well as industry best practices on over 20 criteria. This benchmarking report is used as the basis for follow up discussions between RobecoSAM and company management. Each year we also enter into a structured one-on-one dialogue with over 200 companies interested in improving their sustainability performance. By progressively intensifying our dialogue with companies that demonstrate a strong interest in improving their performance, we maximize the impact of our engagement efforts. Ad-hoc engagement is conducted when controversial business activities or a breach of international norms and standards occur. We believe that our engagement approach, based on the annual RobecoSAM Corporate Sustainability Assessment, opens a direct communication channel with senior management, and is an effective way to maintain an ongoing dialogue with change agents within the companies. Our approach is different from more conventional engagement strategies in that engaging with sustainability leaders, as well as companies that aspire to become sustainability leaders, sets high standards for their industry peers, and has an indirect impact on the laggards by putting competitive forces into play. Many firms use the peer benchmarking feedback report from our assessment to identify gaps and initiate improvements in their business practices. Both financial and sustainability considerations

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shape companies’ success in the long run. RobecoSAM’s integrated approach also helps highlighting for management the importance of managing performance for the long run. An increasing number of firms define inclusion in the DJSI as a corporate goal, as it allows them to gain recognition for their sustainability performance, thus making them more attractive to investors. This serves as an additional incentive for participating in the annual RobecoSAM Corporate Sustainability Assessment.

3d Does (do) the fund(s) have a specific voting policy integrating ESG criteria?

As a signatory of the UN Principles for Responsible Investment (PRI), and in accordance with UN PRI Principle 2 – “We will be active owners and incorporate ESG issues into our ownership policies and practices,” RobecoSAM has always recognized the value of active ownership and engagement. However, as a firm whose key strengths lie in sustainability research, RobecoSAM has historically focused primarily on indirect and direct engagement with companies within the framework of the annual RobecoSAM Corporate Sustainability Assessment. We view this as the most effective means for leveraging our in-house resources and expertise to achieve significant results in an efficient way. As the centre of expertise for Robeco, RobecoSAM took over the responsibility for the 9 person strong team on Governance and Active Ownership of Robeco. This group of voting and engagement specialists acts on behalf of RobecoSAM when engaging with companies on sustainability topics. Voting Policy RobecoSAM buys shares in companies, thereby making it a co-owner of these companies. Each share entitles the owner to vote at shareholders' meetings. The execution of voting rights is an important component of a well-functioning corporate-governance system. RobecoSAM takes its responsibility by voting at shareholder meetings worldwide. By making active use of this right, we can increase control over the company’s management and improve the company’s sustainability, which may eventually contribute to higher shareholder value. RobecoSAM AG bases its voting policy on the principles of the International Corporate Governance Network (ICGN). This is an internationally recognized code for good corporate governance, the basic principles of which allow sufficient scope for assessing companies according to local standards. The national laws and codes of conduct for corporate governance, such as the Nederland’s Corporate Governance Code in the Netherlands, which was anchored in legislation in 2009, are leading in the assessment of companies. Circumstances specific to individual companies also play a role in this. Some of the ICGN Corporate Governance Principles are also covered by the annual RobecoSAM Corporate Sustainability Assessment, which serves as the basis for engagement through intensive dialogues with companies on their ESG performance. RobecoSAM votes for all investment funds for which the costs of voting are not expected to have a noticeable, negative impact on investment results. Each year RobecoSAM AG determines for which of its investment funds it is cost effective to exercise its proxy voting rights. We can also offer proxy voting for clients with segregated mandates who wish to incorporate proxy voting in their investment strategies.

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To avoid unnecessary costs and to increase the efficiency of the voting services in the interests of our clients, RobecoSAM uses an electronic voting platform to cast votes. This platform is used to vote at most meetings, but in a few cases RobecoSAM attends the annual general meeting (AGM) to cast votes. Electronic voting is an efficient way of voting by proxy. From a cost perspective it is not efficient to conduct an extensive analysis on every specific issue for every shareholders’ meeting in order to determine how to cast our vote. Therefore RobecoSAM AG uses independent voting advice from Glass Lewis, an international proxy voting advisor. The RobecoSAM Governance and Active Ownership team compares the specific voting advice with RobecoSAM AG/Robeco’s corporate governance policy. In case of controversial or important agenda items, the responsible portfolio manager at RobecoSAM AG is consulted to discuss the vote. RobecoSAM AG is ultimately responsible for deciding on how to vote on each issue. In a number of markets worldwide, shares are blocked for sale during a certain period of time if the voting rights attached to the shares are executed. The blocking of shares limits the trading possibilities of the portfolio managers and may, therefore, also harm the performance of the investment portfolio. In such cases, RobecoSAM AG may determine that share blocking is detrimental to investment performance, and will decide not to execute its voting rights because it is not in the best interests of its clients. In addition, in order to complement ICGN Voting Principle 1 “Sustainable Value Creation“ and 3 “Good citizenship, relations with stakeholders and the ethical business conduct” RobecoSAM AG will support shareholder resolutions aimed at improving governance, social and environmental performance of companies on a case-by-case basis. Promoting Best Practices RobecoSAM employs a unique approach to engagement by conducting a comprehensive annual Corporate Sustainability Assessment to measure the sustainability performance of over 2000 companies. Our annual questionnaire acts as a tool to encourage improved disclosure on key sustainability issues of interest to long-term investors and offers companies a blueprint of industry best practices in the areas of sustainability and corporate responsibility. As stated above, companies participating in the annual Corporate Sustainability Assessment receive a benchmarking report from RobecoSAM showing their own sustainability scores against their respective industry’s average and against the industry’s top score. This report provides the company with insights into its strengths and areas for improvement in relation to its industry and peers. These results trigger contacts with senior managers and members of the executive management and board of directors. Many companies use RobecoSAM’s questionnaire as a guide to understanding latest sustainability issues and best practices and to implementing these into their strategic priorities and core business processes. Some companies even publicly disclose the completed questionnaire. The publication of the RobecoSAM screening methodology, criteria, and questions used to measure a company's sustainability performance is a powerful vehicle used by RobecoSAM in order to create awareness and competition encouraging the continuous improvement of corporate sustainability. By actively engaging with stakeholders in public forums, industry-wide initiatives and global standardizing efforts, RobecoSAM promotes excellence and best-practices in the sustainability investment world.

RobecoSAM publishes its voting policy and voting reports on the website:

Voting Reports

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3e Does (do) the fund(s) engage in securities lending activities?

If yes,

(i) is a policy to recall the securities in place in order to exercise the voting rights?

Yes, RobecoSAM recalls securities in securities lending in order to exercise voting rights. (ii) does the counterparty selection process integrate ESG criteria?

The counterparty selection process does not integrate an ESG criteria. Securities lending between the fund and the borrowers is processed via the agent SSB (State Street Bank) who is responsible for the borrower selection, the collateral management, the asset auction and the operations. The activities of the portfolio manager are not impacted by securities lending. Listed below are collateral requirements and selection criteria:

State Street (SSB) as Custodial Lending Agent (assets custodied with State Street). SSB will be responsible for selecting and monitoring borrowers according to GAM policy

which will promise diversification of risk through selection of multiple borrowers. SSB will be responsible for the Collateral Management (bi-party with SSB or Tri-Party

through ext. Collateral Agent), t.b.d. during project phase. SSB is a specialised first class securities lending agent which guarantees a secure setup

with highly standardised lending and collateral management processes. SSB as Custodial Lending Agent will reflect additional advantages in terms of setting up

Operational- and IT connectivity, as well as Trading and Collateral facilities. Accordingly operational risks will be reduced.

The collateral requirements are determined as follows: government bonds from G10 countries with a margin of 5% over the value of the loaned securities.

Collateral is held separately with State Street Custody or through Tri-party arrangements. Daily marking-to-market of the collateral positions. SSB offers pre collateralization – collateral has to be delivered by the borrowers to SSB

before any securities are delivered by the funds to the borrowers. Only borrowers which have been approved by SSB and GAM participate in the lending

program. The counterparty risk is therefore further mitigated by the diversification of borrowers and will therefore not differ to the previous set up.

Additionally SSB offers an indemnification to the funds. In the case of a borrower default, SSB will indemnify the funds for any shortfall in collateral.

GAM monitors and supervises the setup and the involved parties systematically and independently, including the quality of the borrowers, the positions on loan, the collateral, and the operational processes.

Tailor-made reporting according to the clients need.

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3f Does (do) the fund(s) use derivative instruments?

If yes describe,

(i) their nature (ii) the objective(s) (iii) the potential limits in terms of exposure (iv) if appropriate, their impact on the SRI quality of the fund

RobecoSAM's sustainability strategies may invest in derivative instruments such as options, futures, currency forwards, etc. These instruments are primarily used for hedging purposes, the steering of currency exposure and the short-term management of cash flows. RobecoSAM’s internal guidelines permit investment in FX forwards and equity futures. All other derivatives are currently not allowed. Where exposure is calculated by means of the market value of positions, the positions on financial derivatives are converted into equivalent positions on the underlying assets. Therefore, eligible derivatives exposure is in scope when calculating exposures versus internal limits. Derivative financial instrument within the fund structure have a general legal global limit to a maximum of 100% of the fund’s assets. Although these instruments may be used, they are not a key component of RobecoSAM’s investment approach.

3g Is a share of the fund(s) invested in unlisted entities pursuing strong social goals?

If yes, please provide a brief description of the objective(s) of this investment, in no more than one or

two sentences.

RobecoSAM's sustainability strategies exclusively invest in listed equities. In order to service redemptions RobecoSAM takes into consideration the stocks' daily liquidity as well as the market capitalization.

Section 4. Controls and ESG Reporting

4a What internal/external control procedures are in place to ensure the compliance of the portfolio

with the ESG rules defined in section 3 of this Code?

State who is carrying out the controls, their frequency and within which timeframe the fund(s) have to

comply should a breach be detected.

Once a company is selected as a member of the RobecoSAM investment universe or the DJSI, it is continuously monitored for its corporate sustainability performance. The objective of the monitoring process is to verify a company’s involvement and management of critical environmental, economic and social crisis situations that can have a highly damaging effect on its reputation and its core business. In addition, the consistency of a company’s behaviour and management of crisis situations is reviewed in line with its stated principles and policies. The Media

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& Stakeholder Analysis can lead to the downgrading of a company’s sustainability score, regardless of how well the company performed in the annual RobecoSAM Corporate Sustainability Assessment. When an issue or crisis situation arises, prior to making a decision to downgrade a company’s sustainability score, RobecoSAM evaluates its impact and the Quality of Crisis Management:

Impact Evaluation The extent of the crisis within the company, geographically and in the media is monitored. As a result, the impact of the crisis on the reputation of the company and its core business is assessed. If the impact evaluation of the crisis is far reaching, covered worldwide in the media or is an important concern for the company, then the second step is an analysis of the quality of the company’s crisis management. Quality of Crisis Management RobecoSAM monitors how well the company communicates, informs the public, acknowledges responsibility, provides relief measures, involves relevant stakeholders and develops solutions to preventing a similar crisis in the future. In this context, RobecoSAM Research weighs the severity of the crisis in relation to the company’s reputation and quality of crisis management.

If the crisis management of an important issue is considered poor from a sustainability point of view, its sustainability score can be downgraded. A downgrading of a company’s sustainability score may not necessarily lead to an automatic exclusion from a fund. However, it may have a negative impact on the overall stock valuation, making it less attractive for continued inclusion in the investment portfolio. With regard to the DJSI, all decisions go through the Dow Jones Sustainability Index Committee. If deemed appropriate, the company can also be removed from the DJSI. RobecoSAM informs the affected companies about their exclusion from the Index. RobecoSAM does not apply minimum sustainability criteria to the stocks held in its investment funds. Rather, RobecoSAM focuses on the integration of sustainability measures into the financial valuation of a company. We use a “best in class” approach for the core strategies, as well as for the sustainability indices, which are based on our annual Corporate Sustainability Assessment to identify sustainability leaders within each industry. This is done deliberately to promote an overall development in the direction of sustainable corporate behaviour, including for those companies in industries that are typically labelled as unethical/unsustainable (Oil and gas, Alcohol, Tobacco, etc.).

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4b Please list all public media and documents used to inform investors about the SRI approach to the

fund, and include URLs. This should include a link to the detailed, no more than 6 months old, list of

holdings of the fund(s).

Product Publications frequency Format Language

Factsheets monthly PDF and HTML German, English, French, Italian, Spanish, Dutch

Fund Brochure ad hoc PDF, HTML and print

German, English, French, Italian

Monthly Manager Report monthly PDF English

Annual Report yearly PDF and HTML German, English, French,

Italian, Spanish, Dutch

Semi-annual report semi-annual

PDF and HTML German, English, French, Italian, Spanish, Dutch

Prospectus ad hoc PDF and HTML German, English, French,

Italian, Spanish, Dutch

Corporate Publications frequency Format Language

Sustainability Yearbook yearly PDF, HTML and print

English

RobecoSAM Monthly Newsletter monthly HTML German, English

Sustainability Studies / White Papers

ad hoc PDF, HTML and print

German, English

RobecoSAM Foresight monthly HTML and PDF German, English

RobecoSAM Insight 3-4 times per year

HTML and PDF German, English

Publications regarding the product capabilities such as prospectus, factsheets, holdings and brochures for a specific fund can be accessed via the RobecoSAM webpage. Chose a strategy, and click on the respective link in the menu “Learn more”.

Holdings can be accessed directly under this menu.

Factsheets and other legal publications such as annual reports and prospectus: The following link leads to the online platforms of the respective legal Management Company, http://www.robeco.com/en/professionals/products/index.jsp, where the documents can be downloaded after a search for fund name. The RobecoSAM Yearbook can be found in digital form and in form to download on the RobecoSAM Webpage under “Sustainability Insights”: http://www.robecosam.com/en/sustainability-insights/library/the-sustainability-yearbook.jsp RobecoSAM studies and white papers, Foresight, Insight and Flash can be found under “Sustainability Insights”: http://www.robecosam.com/en/sustainability-insights/index.jsp The RobecoSAM Newsletter is on a subscription basis. The registration form can be filled in online: http://www.robecosam.com/en/sustainability-insights/library/newsletter.jsp

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Additional

If applicable, specify what the amount of donations and the percentage of management fees that the

fund gave to charities in the last year.

The fund does not donate via the management charge.

_______________________________

COMMITMENT FROM EUROSIF AND THE NATIONAL SUSTAINABLE INVESTMENT FORUMS

Eurosif is responsible for maintaining and publicising the Transparency Code.

Eurosif promotes received responses to the Code on its website.

Eurosif maintains a “transparent” logo that is awarded to those funds complying with the Code and whose answers have been sent to Eurosif. Complying funds can use this logo in their marketing collateral, in accordance with the Logo Specifications Manual (see. www.eurosif.org) and provided the Code is up to date.

Eurosif commits to reviewing the Code. The process for reviewing the Code will be open and inclusive. European SRI Transparency Code

ABOUT EUROSIF

The European Sustainable Investment Forum (Eurosif) is the leading European membership association

whose mission is to develop sustainability through European financial markets. Eurosif works as a non-

for-profit partnership of the national Europe-based national Sustainable Investment Forums (SIFs) with

the support and involvement of Member Affiliates.

Eurosif Member Affiliates include a range of organisations covering the value chain of the sustainable

investment industry, from institutional investors, asset managers to financial services providers, ESG

analysis firms, academic institutes and NGOs.

Eurosif speaks authoritatively and broadly on SRI (sustainable and responsible investment) issues. The

main activities of Eurosif are public policy, research and creating platforms for nurturing sustainable

investing best practices. For more details, please see www.eurosif.org.

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National sustainable investment forums in Europe to date include:

Dansif, Denmark

Finsif, Finland

Forum Nachaltige Geldanlagen* (FNG) e.V., Austria, Germany Liechtenstein and Switzerland

Forum per la Finanza Sostenibile*(FFS), Italy

Forum pour l’Investissement Responsable* (FIR), France

Norsif, Norway

Spainsif*, Spain

Swesif*, Sweden

UK Sustainable Investment and Finance Association* (UKSIF), UK

Vereniging van Beleggers voor Duurzame Ontwikkeling* (VBDO), the Netherlands

*Member of Eurosif

For further information on Eurosif or more details on the European SRI Transparency Code, please look

at our website, www.eurosif.org and contact Eurosif at +32 (0)2 274 14 35 or by email at

contact@eurosif.org.

Eurosif A.I.S.B.L. Avenue Adolphe Lacomblé 59 1030, Schaerbeek Tel.: +32 (0)2 274 14 35

Disclaimer – Eurosif does not accept responsibility or legal liability for errors, incomplete or misleading

information provided by signatories in their responses to the European SRI Transparency Code. Eurosif

does not provide any financial advice nor endorse any specific funds, organizations or individuals.