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1. Please provide your ESG-related policies. Please provide a formal statement of your ESG-related policies if you have one.

We believe that delivering the best investment outcomes for our clients over the long term depends on securing a prosperous and sustainable future.

Our primary responsibility is to help our clients to achieve their long-term investment goals. We believe this is only possible if we secure a prosperous and sustainable future into which to invest. This is why our purpose as a firm is to invest and to advocate for a better tomorrow – to achieve better returns for our clients as well as a better future for our planet. For us, sustainable investing means delivering what we call sustainability with substance. In other words, our approach to sustainability and addressing environmental, social and governance (ESG) risks and opportunities must be evidence-based and purposeful.

There are two policies which govern the ESG space at Ninety One.

Ninety One's describes our approach to sustainability. It covers the full sustainability framework at Ninety One, which comprises three core components: Invest, Advocate and Inhabit.

Invest: We integrate the assessment of ESG risks into our portfolios by deepening our understanding of externalities and improving our analysis and assessment of the risk they present.

Advocate: We seek to raise awareness of the need to fund the transition to a sustainable net-zero future in a fair and inclusive way, particularly in emerging markets.

Inhabit: We work to improve the sustainability of our operations and to support charities and community projects that are important to the team at Ninety One.

Ninety One's sets out our stewardship principles and approach to active ownership, including engagement and proxy voting. Our engagement approach is driven by our goal to preserve and grow the real value of the assets entrusted to us by our clients over the long term. We take a targeted approach, prioritizing engagements where we can exert influence. Where we believe engagement is ineffective or companies are not committed to change, we may use the ultimate lever we have as an investor, which is to reallocate our capital. Ninety One votes at shareholder meetings throughout the world as a matter of principle.

Both policies are reviewed and updated biennially or more frequently as required.

2. Are sustainable investing and ESG factors integrated into your investment process and portfolio management decisions? If yes, please provide details.

Our commitment to incorporate ESG at Ninety One is ‘investment-led’; each of our investment teams integrates and prioritizes ESG considerations in accordance with its investment philosophy and processes. Within 4Factor, we believe that non-financial information should be analyzed in a consistent manner in the same way as traditional financial data, and ESG integration within the process has therefore up to this point been most robust during fundamental analysis.

In our sustainability integration, we aim to unlock the alpha potential these opportunities may represent or mitigate risks on the downside, be it financial or reputational. The assessment of ESG materiality in companies is then incorporated into our decision making and portfolio construction processes. We believe there are limits on what can be achieved without fundamental analysis with respect to understanding and, where possible, pricing sustainability risks into investment decision making.

Alpha model

While we monitor third party ESG ratings, we have not incorporated them into our alpha model up to this point as we believe doing so would lead to an anchoring bias and offer limited utility as sources of uncorrelated alpha, as they are backward looking, lagged and to some extent subjective. Furthermore, exclusionary screens based on ESG ratings at this stage of the investment process could also reduce the available investment opportunity set, and risks exacerbating behavioral biases such as crowding, saliency and anchoring. We are actively exploring, however, if and to what extent non-financial information can add value in our alpha model.

Fundamental analysis

ESG integration in our process is most effective during fundamental analysis, where subjective ESG factors are assessed and incorporated into the investment research and case, where relevant. We believe there are limits on what can be achieved without fundamental analysis with respect to understanding and, where possible, pricing sustainability risks into investment decision making. We integrate sustainability to unlock the alpha potential these opportunities may represent or mitigate risks, be it financial or reputational.

To systematically analyze ESG information, we prioritize materiality and impact for both opportunities and risks. Our ESG assessments leverage a materiality matrix through three-pillars across ten key sustainability challenges, ranked high, medium or low, depending on the level of perceived risk.

This process is guided by a bottom-up sector sustainability framework informed by our team’s specialist sector knowledge. Recognizing the breadth and specificity of challenges and opportunities inherent to each sector, we tailor our approach to ensure relevance. For example, carbon is an obvious challenge for sectors like materials and energy, but it’s far less of an issue for, say, healthcare. In healthcare, we are far more concerned about ethics and integrity.

We have found that insights generated from our materiality matrix help us to identify areas where financial returns could be under threat or improved, and we utilize these within our fundamental research. The framework also provides a basis for guiding the investment team on engagements on the most material sustainability challenges for companies in each sector, to help catalyse a positive alpha outcome or otherwise mitigate risk, be it financial or reputational.

The ESG considerations considered most material in our investment process vary by sector but broadly include environmental issues such as carbon emissions and climate transition risks, social factors like ethics, labor conditions, and customer safety, and governance elements such as board oversight and executive compensation. ESG analysis is an ongoing part of our fundamental research and due diligence on both potential and current investments.

Transition Plan Assessment

Alongside our materiality matrix, another key development for us has been the development of our Ninety One Transition Plan Assessments that scores our heaviest emitters on three key principles: level of ambition, credibility of plan, and implementation of plan. This is used to assess heavy emitting companies within the portfolio.

When committing to net zero as a firm, we were conscious that most companies globally, but particularly in emerging markets, did not yet have a clear plan on how they are going to decarbonize by 2050. Therefore, we were keen to ensure, in our role as shareholders, we could encourage, engage and measure the high emitters in our portfolios on the progress of their transition to Net Zero. Where possible, we want to go on the journey of transition alongside the heavy emitting companies that we hold across our firm. Given the bias of these companies towards emerging markets, this is particularly relevant for this mandate.

To ensure that we do this with integrity, we have developed an in-house, firm wide, ‘Transition Plan Assessment’ (TPA) that scores our heaviest emitters on three key principles: level of ambition, credibility of plan, and implementation of plan. This is used to assess heavy emitting companies within the portfolio. It helps to inform and prioritize our company engagements with those where climate is likely to be a material risk, as well as deepening our understanding of their business and its vulnerability to a disorderly transition.

We undertake TPAs for all securities in a high-emitting sector, as defined by The Institutional Investors Group on Climate Change (IIGCC) as well as those, once invested, that contribute to the top 50% of firm-wide financed emissions.

Engagement

As active stewards of our client's capital, we believe it is not only our duty to engage with companies, but that these engagements can form a critical input in our fundamental research.

Our engagement strategy targets specific holdings and material ESG themes that are significant to the firm, the investment team, and our clients. We do not engage with every company in our portfolio. We are also realistic with how much influence we can have, as this can be dependent on our shareholding in the company. Therefore, the trigger to engage with a company is if we believe that our involvement will mitigate a material risk (financial or reputational) and/or catalyze an alpha-positive outcome. Our approach to engagement therefore prioritizes companies that have experienced a development that could potentially materially impact their intrinsic value or proactive engagement where we believe we can add to shareholder value. For instance, the work undertaken through our TPAs combined with the deep, subjective understanding of our investment analysts, can help us to pre-empt potential issues through engagement. We document dialogue with companies, and monitor and report on engagements, measuring success and outcomes against initial objectives, such as commitment to, or enactment of, actual changes by management in strategy or reporting, disclosure and transparency. We also report on goal progress to our clients.

Portfolio construction

In part, portfolio size is determined by a sustainability analysis. Sustainability considerations, which inform our fundamental conviction, can potentially influence position sizes. Ultimately, we will not own a company where there are sustainability risks that materially affect the investment case, and any increase in such risks will trigger a reassessment of our broader investment position in the company.

ESG Risk monitoring

It is worth noting that while our portfolio managers have ultimate responsibility for monitoring and maintaining an optimum risk/reward balance in their portfolios, including ESG risks, further guidance and support is provided by the Ninety One Investment Risk team (including dedicated ESG specialists), which oversees and challenges the investment process.

Ninety One’s ESG risk framework seeks to monitor, assess and challenge on ESG risks in investment portfolios, including reputational risks. The purpose of the ESG risk process is to ensure ESG integration is in place within investment processes and strengthen existing integration efforts by testing its robustness through appropriate challenge. Note that the aim is not to expunge ESG risk from Ninety One portfolios, rather to ensure it is identified and understood, and that relevant exposures are justified and risks mitigated in terms of overall client and stakeholder outcomes. ESG risk reporting forms part of the monthly Investment Risk Committee (IRC), which oversees the governance of all aspects of investment risk. ESG risk reporting also forms part of the reporting to the Sustainability Committee which oversees the overall response by the business to its commitment to ESG integration, including the effectiveness of the risk component.

3.a. Are you a signatory to the UNPRI?

Yes.

3.b. If you are signatory to other coalitions, please list them.

As a global business, we welcome the development of stewardship codes across the world. We believe that these codes are key to enhancing the long-term success of companies, through a better quality of engagement and improved transparency in regional markets. We are currently an endorser/signatory to the following codes:

• UK Stewardship Code
• Code for Responsible Investment in SA (CRISA)
• Singapore Stewardship Principles
• ISG (Investor Stewardship Group) US Stewardship Principles
• Hong Kong Principles for Responsible Ownership
• Japanese Stewardship Code
• Korean Stewardship Code

Please refer to Appendix 2 within our attached for further details.

3.c. Indicate any other international standards, industry guidelines, reporting frameworks, or initiatives that guide your responsible investing practices.

We seek to contribute meaningfully to the conversation on sustainability and to encourage a deeper focus on sustainability-related issues in all of the jurisdictions where we invest. We may collaborate with other investors as part of an engagement strategy if it can contribute to achieving our engagement objectives. Our membership of regional and global organizations facilitates this.

The table below details our firmwide collaborative partnerships and our role:

4. Please describe how ESG oversight and integration responsibilities are structured at your firm, including the process for escalation of key ESG issues. Also, if applicable, describe how responsible investment objectives are incorporated into individual or team employee performance reviews and compensation mechanisms.

The following chart provides an overview of the governance of our sustainability approach across Invest, Advocate and Inhabit:

_{¹DLC: Dual Listed company}

Our Sustainability team is the central custodian of the firm-wide sustainability framework and ecosystem. They report into the Sustainability Committee which is responsible for the internal oversight of sustainability, including monitoring progress and ensuring alignment of focus, strategy and integrity through the business. The Sustainability Committee reports to the Executive Management team, which in turn reports to the Ninety One Board and the Sustainability, Social and Ethics Committee (SS&E).

A detailed description of each of the functions mentioned above and how they assist with ESG integration and analysis across the firm is given in the following table:

5. How do you obtain ESG information/data (e.g. public information, third party research, reports and statements from the company, direct engagement with the company)? Please provide specific details of what information is obtained from each source, and how this information is acquired.

Our sustainability team and investment risk team look to ensure that the business has appropriate access to ESG data, so that investment teams are equipped with the knowledge, research and tools to fully integrate ESG into their investment processes. The data that we have access to is used to support understanding of material information. We use a combination of proprietary and external research, which is integrated and considered in various ways depending on the investment team process for example through scorecards, through use of investment data platforms, and use in research reports.

The table below summarises the primary ESG data sources that we make use of:

6. What channels do you use to communicate ESG-related information to clients and/or the public? Do you produce thought leadership (written reports and publications)? If so, is the information available to the public? Please provide links, if applicable.

Transparent reporting and communication with clients and stakeholders are key features of our “sustainability with substance” approach. We believe that being transparent about our stewardship approach is important, and this is reflected in our reporting to clients. We publish several regular and bespoke reports, which include:

Sustainability and Stewardship report

The includes progress on integration across the investment teams over the year, engagement details, advocacy work, voting data, case studies and market trends and is published annually covering the previous year to 31 March.

PRI Transparency and Assessment reports

As a signatory, it is mandatory to report annually on our responsible investment practices through the PRI Transparency report. Our latest PRI reports can be found on our website via the following link: 

Task Force on Climate-related Financial Disclosures (TCFD)

Ninety One formally pledged its support for the TCFD in September 2018 and this report sets out how we disclose our exposure to and management of climate risk, using the TCFD framework. Our TCFD report can be found within our (pages 38-51)

Online voting disclosure

Voting decisions are disclosed publicly on a monthly basis on the Ninety One website and can be found our website via the following link: .

Annual Sustainability Reports

With regard to our sustainability-focused products, our annual sustainability reports present significant developments throughout the year, including environmental and sustainability metrics for the portfolios and underlying holdings, details on proxy voting (where applicable), as well as engagement goals and progress:

Quarterly Sustainability Reports

For our non sustainability-focused products, our quarterly sustainability reports provide an outline of the key sustainability risks and opportunities and cover the investment team's approach to sustainability integration; key engagements; proxy voting activity; portfolio climate risk analysis and portfolio characteristics.

Other sustainability disclosures

We publish various sustainability disclosures on our website as per regulatory requirements i.e. SFDR disclosures.

Planetary Pulse

This report reveals the findings from new primary research into transition finance. It is based on a survey of 300 senior professionals at asset-owner institutions and advisors around the world, including pension funds, insurers, endowments, foundations, central banks, sovereign wealth funds, and consultants.

Investment Institute

Our is an engagement platform that delivers strategic investing insights and analysis to our clients across asset classes, investment strategies and borders. 

The Investment Institute provides in-depth analysis and research on key geopolitical, economic and investment trends. Its work draws on our firm’s investment capabilities and partnerships with leading academics and external practitioners, and seeks to empower clients with insight and knowledge.

Portfolio resilience, sustainability, and ESG applied to investing have been central themes of the Institute’s work and have culminated in the publication of annual journals and papers. Below are just a few of our research, reporting and thought leadership papers relating to Sustainability that we have produced. All are both, internal and public-facing communications.

The Investment Institute mobilizes Ninety One’s firm-wide expertise and our substantial global network of specialist partners to generate proprietary insights on the global economy, markets, geopolitics and asset allocation. The Institute seeks to play a full and active role in the global conversation on sustainable investing. From aligning a portfolio with the decarbonization growth trend to ensuring a fair clean-energy transition for all, Ninety One’s portfolio managers and analysts explore sustainable investing across asset classes and investment approaches.

An important feature of our Investment Institute is the direct link between the research insights it generates, and portfolios managed across the firm. The Institute works closely with all the firm’s investment capabilities and has strong Executive Management support for its work.

Podcasts

Through our ‘The Big Picture’ podcast channel we provide interviews and viewpoints on various ESG related topics.

7. Do you have periodic reviews of your ESG process/approach to assess its effectiveness? If so, how frequent are the reviews? What are the results? What would cause you to disregard ESG issues in your investment/analysis decisions?

Despite never deviating from our philosophy we always look to enhance and evolve each stage of our investment process through constant review, to provide the best possible outcomes for our clients. The 4Factor team hold an annual off-site conference, typically held in September, during which they review the 4Factor framework, including the approach to ESG integration, and its effectiveness over the past year.

Oversight for responsible investing lies with our internal Sustainability Committee. This robust and transparent governance structure is necessary for effective stewardship and oversees all activities with respect to stewardship and ESG at Ninety One. The Sustainability Committee meets quarterly to review our progress and activities in relation to ESG integration, stewardship, engagement, advocacy, sustainability and climate risk, regulation and other related matters. This committee also reviews and approves new policies as well as changes to existing policies. Investment team heads are required to report to this committee on a regular basis.

A comprehensive assessment of E and S and G is considered and wholly integrated within each of our investment capabilities, ensuring these factors are duly considered when any investment decision is made. Therefore, any decision to buy or sell due to an ESG issue would not be made on ESG assessments alone, but rather as a result of a thorough investment process of which ESG analysis is a part.

If any investment decisions are to be vetoed the decision would be made by the Sustainability Committee (and/or the Sustainable Investment Advisory Forum for our sustainability-focused products) after a thorough due diligence process.

8. Describe how you identify, assess, and manage climate-related risks, and whether climate-related risks and opportunities are integrated into pre-investment analysis.

As an active global investment manager, we need to think about transition risk and physical risk from climate change in the context of all our stakeholders. This means our staff, our clients, our shareholders and the companies in which we invest. The ���˴�Ƭ risk to our business is a material destruction of value in the underlying companies to which we allocate our clients’ capital; for this reason, deep integration of climate change risk in our investment process is the most important protection for our business in the long term.

We look to integrate climate change considerations, including both transition and physical risks where material, within the investment decision making process. This includes developing ways to assess climate change risk exposure of our investments and portfolios, engage with investee companies on climate change, and support industry initiatives that encourages especially greater and higher quality disclosure of climate change data. Our internal focus is currently on integration of climate change considerations within our various investment strategies.

We have also developed the ability in house to measure portfolio carbon metrics aligned with the recommendations of the Taskforce for Climate-related Financial Disclosures (TCFD), and the Partnership for Carbon Accounting (PCAF) standard. After development of a proprietary Portfolio Climate Risk Tool, which helped us understand the nuances, methodologies, and data challenges, we have transitioned to integrating carbon data with our portfolio management tools.

The TCFD metrics include:

• Weighted Average Carbon Intensity, measured in tons of carbon dioxide equivalents per million USD revenue
• Portfolio Carbon Footprint, measured in tons of carbon dioxide equivalents per million USD invested

Using carbon data from MSCI as a starting point, the tools support identification of companies that are material contributors to portfolio carbon metrics, allowing investment teams to focus their analysis on exposure to transition and physical risk. Importantly, the tool provides detailed coverage of scope 1, 2 and 3 emissions and, where data doesn’t exist for a company, it will provide an estimate based on an industry average. Additional data we are integrating includes qualitative metrics to support in understanding companies' climate-related targets, and indicators of the quality of climate strategy.

In summary, the tools and data help us understand:

• Highest emitters and largest contributors to portfolio emissions
• How the portfolio compares relative to the benchmark
• Details on corporate climate-related targets and progress on transitioning to a low carbon world

The emphasis is always on using the available tools for an integrated understanding of the risks, including
identifying companies that are least prepared for a transition to a low carbon world.

Transition Plan Assessment

At a firm level, we have developed a process to assess the transition risk of the biggest emitting companies in our house portfolio. When committing to net zero, we were conscious that most companies globally, but particularly in emerging markets, do not yet have a clear plan on how they’re going to decarbonize by 2050. Therefore, it is our role as shareholders to encourage, measure and engage the high emitters in our portfolios on their transition and to go on the journey of transition alongside them, with a special focus on emerging markets. To ensure that we do this with integrity, we have developed an in-house ‘Transition Plan Assessment’ (TPA) that scores our heaviest emitters on three key principles: level of ambition, credibility of plan, and implementation of plan.

Our TPA tool uses indicators derived from best-in-class disclosure and measurement frameworks, including the
Climate Action 100+ benchmark, Transition Pathway Initiative, CDP climate data, InfluenceMap and IIGCC guidance. We have built on these frameworks to incorporate, or emphasize, factors that we consider imperative for a successful transition, such as the financial viability of the plan or the approach to just transition. We explicitly seek to avoid rewarding companies using divestment to achieve their emissions targets.

Three companies within the Emerging Markets Equity Strategy - Samsung Electronics, Vale, and WH Group— are also among the firm’s top emitters. Transition Plan Assessments (TPAs) have now been completed for all four. Over the past year, we have also engaged with an additional ten portfolio companies on climate change and their transition strategies.

Our current 4Factor investment process includes comprehensive analysis of the carbon emissions and transition pathways for all securities in a high-emitting sector, as defined by The Institutional Investors Group on Climate Change as well as those, once invested, that contribute to the top 50% of firm-wide financed emissions. Carbon transition is highlighted as a material risk for many sectors, necessitating both a stock and portfolio-level approach. We are now working on ways to expand from our portfolio carbon risk profile analysis to place greater emphasis on transition alignment and the quality of companies’ transition plans. Last year, many of our investment professionals participated in a bespoke program with Imperial College that focused on climate risk. This has helped intensify debate organization-wide and within our investment team leading us to begin developing our own transition alignment frameworks at a strategy level. There will continue to be a central effort from Ninety One’s dedicated Sustainability team to support and guide all investment teams on this. This will feed into the objectives of individual strategies and guide engagement with clients around their own net zero agendas. Our approach to addressing climate change includes a clear focus on materiality.

The 4Factor specific Transition Plan Assessment for high portfolio emitters then provides a holistic assessment looking at emissions intensity, reduction targets if these are science based, TCFD reporting alignment, net zero ambitions, transition pathways, and alignment of management incentive structure linked to achievement of goals. We categorize these high emitters into five categories, to align with the IIGCC energy transition criteria: “Achieving Net Zero”, “Aligned”, “Aligning”, “Committed” or “Not aligned” as appropriate.

9. Describe the climate-related risks and opportunities you have identified over the short, medium, and long term.

Our approach to assessing climate change sits within our . There have been no significant updates over the period, however we are focused on making progress with our strategic engagements through carefully developed engagement plans, clear objectives and milestones, prudent escalation strategies and thoughtful advocacy work to improve the enabling environment.

We recognise that climate change presents opportunities and risks to our products, investment strategies and business. We believe climate change is likely to be one of the ���˴�Ƭ commercial challenges that our organisation has faced in its lifetime. Our strategy has always centred around delivering strong returns for our clients through innovative and targeted products. We therefore put sustainability with substance, with a focus on climate risk, at the core of our business strategy.

Our general aim is to ensure that robust ESG integration processes highlight material climate risks (both physical and transition risks) and prompts our investment teams to analyse and address them as part of their fundamental research. Our approach is based on the belief that over time, the market will increasingly price negative externalities into the value of securities. We believe that with better informed analysis to price climate risk our allocation of capital will favour companies and countries working the hardest to tackle climate risk. The strength of our investment outcomes benefits from a deep understanding of material climate-related risks and their potential to affect value.

We joined the Net Zero Asset Managers Initiative in 2021. We publicly disclose our targets under Net Zero Asset Managers Initiative in our Sustainability and Stewardship Report. We know this is not an easy road to travel and will be tested in the pursuit of this ambition. Wherever there are constraints, we shall, with determination and ambition, challenge and seek to overcome them.

As an asset manager, we have approached the implementation of this commitment in two ways:

• The first is our footprint: Our own operations, Scope 1, 2 and 3 (category 6). We intend to decarbonize our operations over time by investing in low-carbon energy, encouraging behavior change and supporting initiatives that credibly contribute to a lower-carbon world.
• The second is our handprint: The impact of the portfolios we manage for our clients (Scope 3 - category 15). Our targets cover our entire corporate portfolio. We are engaging with our portfolio companies to set targets and transition plans consistent with a science-based net-zero pathway

At a firm level, we have developed a process to assess the transition risk of the biggest emitting companies in our house portfolio. When committing to net zero, we were conscious that most companies globally, but particularly in emerging markets, do not yet have a clear plan on how they’re going to decarbonize by 2050. Therefore, it is our role as shareholders to encourage, measure and engage the high emitters in our portfolios on their transition and to go on the journey of transition alongside them, with a special focus on emerging markets. To ensure that we do this with integrity, we have developed an in-house ‘Transition Plan Assessment’ (TPA) which is described above.

We are now pleased to have completed 44 TPAs for our highest-emitting investee companies and have established a strategic-engagement process for our highest-emitting companies, linked to the output of these assessments. We have also made good progress against our net zero targets with 10.9% of financed emissions and 26.6% of corporate AUM having Science Based Target initiative (“SBTi”) commitments or targets approved as at 31 March 2024.

10. Describe how you analyze the effectiveness of your investment strategy when taking into consideration different climate-related scenarios, including 1.5 degree and 2 degree Celsius warming scenarios.

Ninety One conducts an analysis of the impact of climate risk from the three TCFD scenarios based on the GHG emissions pathways and the inferred carbon prices developed by the Intergovernmental Panel on Climate Change (IPCC) at a firm level, and for our OEIC fund range. These are the three scenarios and their assumptions:

• Orderly net zero transition scenario: Emissions are reduced in a measured way to meet global climate goals through strict climate policies and via innovation. The outcome includes the impacts of both climate related risk and opportunities. Assumes an average global temperature increase of 1.5ºC in 2100. Model is based on Very low emissions’ IPCC scenario (SSP1-RCP1.9).
• Disorderly transition scenario: Minimal progress is made to reduce emissions by 2030 which results in a delayed knee-jerk reaction from governments, regulators and companies to reduce emissions in the period thereafter. Higher transition risks pervade with policies diverging across countries and sectors creating disorderly
  characteristics companies will need to deal with. The need for innovation and large capital investments albeit at a later stage could impact the profitability of carbon-intensive companies. Assumes an average global temperature increase of 1.5ºC in 2100. Model is based on Very low emissions’ IPCC scenario (SSP1-RCP1.9).
• Hothouse-world scenario: The hothouse-world scenario will materialize if the world continues on its current path over a longterm trajectory. Extreme weather events are more frequent, weather pattern changes will harm food supply leading to vast human migration. Assumes an average temperature increase of 4.3ºC by 2100,
  high emissions’ IPCC scenario (SSP3-RCP7.0).

The corresponding portfolio level impacts are inferred from the exposure to carbon intensive assets in the context of their underlying revenue exposure to physical climate and transition risks. Data from Clarity AI supports this qualitative and quantitative analysis of climate risk impact (physical and transition risks) on our portfolios under an orderly transition, disorderly transition, and a hot-house world scenario.

However, given the impact of physical and transition risk vary considerably depending on a range of factors including sector, location, vulnerability, risk management plan, competitiveness, political context, price elasticity, pass through costs, technology costs over time etc, in general we do not consider mechanistic outputs of scenario modelling to give a full and dynamic picture of the potential risks and impacts over relevant time horizons for different investment strategies. Therefore, we consider the optimal approach for individual companies with potential exposure to manage their risks is through a forward-looking plan for transitioning to net zero and managing climate impacts.

Ultimately, we continue to believe that portfolio managers, supported by their investment teams, are responsible for analyzing climate risks and opportunities within their portfolios and determining how these risks might affect portfolio holdings. We also believe that exposure to climate risks and opportunities should be considered alongside the companies’ ability to manage physical and transition risks and adapt their existing business operations and products to a lower-carbon economy.

11. Do you track the carbon footprint of portfolio holdings? If yes, how frequently? Please provide the results as of December 31, 2023 and describe the methodology and metrics used, including whether you have set targets and/or a net zero objective for reducing the portfolio’s footprint, and comment on any related progress over the
past year.

Yes. 

The analysis below is based on all assessable securities held directly within the portfolio as at the end of the quarter as estimated using the methodology described above. For the purposes of this analysis, where only a percentage of the portfolio is covered as at 31 December 2024, the assessable securities have been reweighted to 100%. This only affects the carbon intensity measure. Therefore, the carbon intensity reflects only the emissions of companies where we have data and may not be reflective of the emissions of the entire portfolio. This quarter we’ve changed the Carbon Footprint measure to align with observed changes in the industry. Using the Partnership for Carbon Accounting Financials (PCAF) guidance, we now use Enterprise Value including Cash (EVIC) to determine the allocation of emissions.

Scope 1 & 2 emissions provide a good proxy for how efficiently a company is managing the carbon emissions directly under its control. Data for Scopes 1 & 2 has decent coverage and is relatively consistent quarter on quarter reflecting portfolio and benchmark changes. However, for many sectors, like oil & gas or automotive companies, Scope 3 accounts for the bulk of emissions. This includes the carbon emissions in both the company’s supply chain and those generated by the company’s products as they are used. Therefore, we also provide Scope 3 data, when this accounts for the most significant portion of a company’s emissions. We would caution that the quality of Scope 3 data is less advanced, it is not reported by all companies and where it is, it may not be calculated on a consistent basis. We use estimates based on sector averages where it is not available or incomplete and are regularly refining the modelling underpinning Ninety One’s climate-risk tool to improve accuracy. This leads to greater variability in the Scope 1, 2 & 3 columns for both the portfolio and benchmark. This means that it is difficult to compare Scope 3 emissions quarter-to-quarter. However, as we aim to have an impact on real world emissions, we believe that engagement priorities can only be set including Scope 3 emissions.

Carbon reduction targets

We do not manage the Strategy to explicit climate related targets. However, as mentioned above, Ninety One's net zero targets currently incorporate our entire portfolio of corporate assets. These targets aim for 56% of AUM and 50% of financed emissions have science based targets and net zero transition plans by 2030 and are applied across the firm's overall portfolio of investments, as opposed to individual strategies. Therefore, the corporates held in this portfolio are part of the scope of these overall targets. We also engage with companies guided by areas identified in their TPAs to influence real-world carbon reduction.

In our drive for low-emitting portfolios, we intend to do more than reduce ‘portfolio carbon’ by simply constructing portfolios that exclude high-emitting companies. If we mechanistically apply an exclusionary process to achieve net zero targets, a consequence is likely to be the creation of portfolios concentrated in asset-light industries without the transition focus on the remainder. As a side-line, we might see certain companies, regions and sectors abandoned to their own devices.

12. What are your firm's emissions as of December 31, 2023? Please provide scope 1 and scope 2 emissions, and, separately, scope 3 emissions if available. Please demonstrate how/whether you are taking steps to reduce these emissions.

Our commitment to sustainability extends beyond integrating it into the way we invest. The third pillar of our sustainability framework 'inhabit', drives our ambition to inhabit our own ecosystem in a manner that ensures a sustainable future for all. This includes the way in which we look after our people and the way we govern our firm. As a long-term investor on behalf of our clients, we are aware of our broader responsibility to society.

Change starts with us, and we are committed to walking our talk in terms of our own sustainability footprint. We enthusiastically take on the responsibility for ‘inhabiting’ our ecosystem in a manner that ensures a sustainable future for all. From the Ninety One Green Team at our offices, through to our work in conservation and communities both globally and in our original homeland of Africa, we support the preservation of our natural world, creating a better tomorrow for future generations.

Running our business responsibly

Ninety One joined the Net Zero Asset Managers Initiative in 2021, committing to reach net zero emissions by 2050 or sooner. We published our transition plan in 2022, which includes 2030 targets for our investments and operations.

As an investment manager, the largest contribution to our carbon footprint is from the investments that we make on behalf of our clients. At the same time, in line with our purpose, we want to contribute to a better world and aim to run our business sustainably. We are committed to reducing emissions across our own operations and locations and have set a 2030 target to reduce absolute Scope 1&2 emissions by 46%. In financial year 2024, our Scope 1 and 2 emissions increased by 3%. However, compared with 2019, our baseline year, our Scope 1 and 2 emissions have decreased by 25%, and we remain on track for our 2030 target.

We recognize our responsibility to play our part in reducing global emissions, and we support the long-term goal of the Paris Agreement to keep the global average temperature increase to below 1.5°C. We use an environmental data collection system to track and manage our direct operational impacts. Over the year, we further improved the accuracy and thoroughness of our data, based on updated carbon emission factors, improvements in data quality and adjustments to previous estimates.

1. _{This table shows our total operational GHG emissions and energy data and is line with the Streamlined Energy and Reporting requirements. Global includes UK emissions. Numbers may not total exactly due to rounding. Base year in 2019 is calculated for the calendar year. FY 2023 and FY 2024 are aligned with Ninety One’s financial year from 1 April to 31 March.}
2. _{Energy consumption in kWh for Scope 1 and Scope 2.}

Our carbon footprint was calculated in accordance with the international Greenhouse Gas (“GHG”) Protocol’s Corporate Accounting and Reporting Standard (revised edition). We measure and report our carbon using both location- and market-based methodologies. We believe this provides the most transparent and accurate view of our operational carbon footprint.

Key carbon numbers FY 2024

• Total tCO2e per £million of adjusted operating revenue, our intensity metric, increased by 37%.
• Global Scope 2 electricity emissions increased by 1% on a location basis. Over half of our Scope 2 emissions relate to our Southern Africa offices, a more carbon intensive location for electricity.
• Our global Scope 3 emissions, which include paper, waste and business travel, increased by 45% to 6,694 tCO2e. This was mostly due to changes in the greenhouse gas conversion factors applied to travel, with some increase in business travel (specifically air travel). A certain amount of travel is required to run our global business, both to meet with clients and engage with colleagues. However, we continue to look at less emissions intensive options for air travel. This will be a focus over the coming period.
• Carbon neutral on a Scope 1, 2 and 3 (Category 6) through our partnership with BioCarbon Partners (see page 70 in our for details)
• Agreed to establish first-of-a-kind ‘wheeling’ arrangement for our Cape Town office in South Africa. ‘Wheeling’ involves the transfer of privately generated renewable energy across the national grid to meet our electricity needs.

Current initiatives

Our employee resource group, Ninety One Green, continued looking at how to implement sustainability initiatives across the business. We maintained our partnership with Giki Zero to engage and educate our employees on their carbon footprints. This included campaigns on COP28 and explaining what it means for individuals rather than corporates and governments.

While decarbonizing our operations remains our focus, we maintained our long-term partnership with BioCarbon Partners (“BCP”) to mitigate 100% of our Scope 1, 2 and 3 (business travel) carbon emissions. BCP is a for-profit social enterprise founded in 2011, working to make forests and wildlife valuable to rural communities in the Luangwa and Lower Zambezi areas of Zambia. BCP does so primarily through the development and sale of carbon offsets, generating revenue used to conserve natural forests in some of Africa’s most important ecosystems. The projects are deeply integrated into local communities, which share in the revenue from the sale of the verified carbon offsets.

We continue to assess viable options for sourcing energy from renewables. This remains a challenge in South Africa, where we have sizeable operations. Nevertheless, we continue to seek to improve our energy efficiency. This has included entering into an agreement with Growthpoint Properties to wheel renewable solar energy from the Constantia Village shopping center in the suburbs of Cape Town for use at Ninety One’s refurbished offices once the refurbishment is complete. This will significantly improve the carbon footprint of this office.

13. For the mandate you manage for Queen’s, what percentage of equity holdings (if applicable) have credible net zero commitments? Please answer on both an equally-weighted and market cap-weighted basis.

We do broadly aim to build portfolios which exhibit lower WACI than the benchmark. However, we also recognize there is more to this topic than current emissions metrics. A critical part of our fundamental investment process it to understand the direction of travel; by assessing the credibility of our target companies’ own commitments and proposed transition pathways.

As a percentage of NAV, 7.4% of the portfolio consists of companies with SBTi commitments, while on an equally weighted basis, this figure is 8.1%. These are commitments demonstrate an organizations’ intention to develop targets and submit these for validation within 24 months. This would be the first step in setting a science-based target.

As a percentage of NAV, 19.9% of the portfolio consists of companies with validated SBTi targets, while on an equally weighted basis, this figure is 16.3%. These companies have clearly defined pathways to reduce greenhouse gas (GHG) emissions, which have been validated by the SBTi.

14. How do you assess the credibility of a company’s emission reduction targets?

As mentioned above, at a firm level, we have developed a process to assess the transition risk of the biggest emitting companies in our house portfolio. When committing to net zero, we were conscious that most companies globally, but particularly in emerging markets, do not yet have a clear plan on how they’re going to decarbonize by 2050. Therefore, it is our role as shareholders to encourage, measure and engage the high emitters in our portfolios on their transition and to go on the journey of transition alongside them, with a special focus on emerging markets. To ensure that we do this with integrity, we have developed an in-house ‘Transition Plan Assessment’ (TPA) that scores our heaviest emitters on three key principles: level of ambition, credibility of plan, and implementation of plan.

Our current 4Factor investment process includes comprehensive analysis of the carbon emissions and transition pathways of our prospective investments that are material to the net zero transition. Carbon transition is highlighted as a material risk for many sectors, necessitating both a stock and portfolio-level approach. We are now working on ways to expand from our portfolio carbon risk profile analysis to place greater emphasis on transition alignment and the quality of companies’ transition plans.

The 4Factor specific Transition Plan Assessment for high portfolio emitters provides a holistic assessment looking at emissions intensity, reduction targets if these are science based, TCFD reporting alignment, net zero ambitions, transition pathways, and alignment of management incentive structure linked to achievement of goals. We categorize these high emitters into five categories, to align with the IIGCC energy transition criteria: “Achieving Net Zero”, “Aligned”, “Aligning”, “Committed” or “Not aligned” as appropriate.

15. What forward-looking metrics do you use to assess an investment’s alignment with global temperature goals?

As an organisation, we believe in transition alignment, and in SBTi as the gold standard for companies to comply with. As a signatory to NZAMI, we are committed to setting out a plan to reach net zero by 2050 or sooner. We are committed to ensuring that 100% of our corporate asset pool (debt and equity) achieves Net Zero by 2050.

At a firm level, we have sought to design net-zero targets for our investment teams aimed at driving real-world carbon reduction and allowing emerging markets to transition in a fair and inclusive manner. To this end, we have set the following target for our investments:

• At least 50% of the corporate emissions financed by Ninety One will be generated by companies with Paris-aligned science-based transition pathways by 2030.
• The proportion of our corporate assets under management covered by Paris-aligned science-based transition pathways will meet the SBTi requirements for Ninety One to obtain a verified SBTi. We calculate this requirement to be 56% of our corporate assets under management with science-based transition pathways by 2030.
• In practice, we will be engaging actively with our highest emitters and largest holdings to maximise the proportion of our corporate AUM with science-based transition pathways.

Whilst the portfolio has no explicit net zero target, we should note that the transition alignment evaluation, enables us to monitor the portfolio from a climate risk analysis perspective, and allows us to actively engage with the companies that are top emitters in the portfolio.

We would expect more of the portfolio through time to be aligned to a net zero pathway.

16. Has your firm produced a Task Force on Climate-Related Financial Disclosures (TCFD) report? If yes, please provide a link to the most recent report.

Yes, Ninety One formally pledged its support for the Task Force on Climate-related Financial Disclosures (TCFD) in September 2018, reinforcing our commitment to climate change.

We have now merged our TCFD reporting within our (pages 38-50) - so that our non-financial reporting sits alongside our financial reporting in preparation for the impending ISSB reporting requirements. Please refer to the recommendations table from page 40, which outlines our progress on each of the TCFD recommendations. The table shows both areas in which we have made good progress and areas where we believe more work is required to fulfil a disclosure requirement to a high standard.

In this reporting period, we made further progress on our disclosures including detailed work on transition finance, TPAs and scenario analysis. We believe this work is crucial to generate meaningful changes in the real world and a just transition for emerging markets.

As per FCA requirements, we have also included additional metrics where required for the assets in scope of the FCA’s UK entity level requirements, which include the AUM of Ninety One Fund Managers Limited and investments managed by Ninety One UK Limited.

To meet new FCA product level requirements, we have also begun reporting TCFD metrics for our UK domiciled OEIC fund range. The outlines how Ninety One’s investment funds within Ninety One’s OEIC series I-IV align to the TCFD disclosures.

As part of the FCA requirements, we have also begun providing specific information on scenario analysis within the documents (as and when they are published). Ninety One has based its analysis of the impact of climate risk on the three TCFD scenarios for greenhouse gas (GHG) emissions pathways and the inferred carbon prices developed by the Network for Greening of the Financial System (“NGFS”) – an orderly transition scenario, a disorderly transition scenario and a hothouse-world scenario.

17. Has your firm produced a Sustainability Accounting Standards Board (SASB) report? If yes, please provide a link to the most recent report.

Not applicable

18. Please provide the composition of your senior leadership team and board of directors, including women and visible minorities. How do you encourage diversity of perspectives and experience?

Across the firm, we have a diverse, experienced and stable leadership team.

Board of Ninety One Ltd and Ninety One plc

The Board of Ninety One Ltd and Ninety One plc (“the Board”) is responsible for, inter alia, the approval and review of the Ninety One Ltd and Ninety One plc group of companies’ (“Ninety One Group”) long term objectives and strategy, approving any dividend payments, ensuring maintenance of a sound system of internal control and risk management and oversight of financial position, investment performance and operations.

The Boards consist of six Non-Executive Directors and two Executive Directors.

The ‘Terms of reference’ for the board committees (which includes a description of the committee’s decision making powers, responsibilities, and name and position of attendees) are available from our website on the following .

Executive Management

The Board, with Executive Management, agree the strategy for the business and ensure the right structures are in place to achieve success. Executive Management regularly reviews and monitors progress against Ninety One’s strategic objectives. Where factors arise which may impede (or accelerate) the execution of these priorities, they are carefully considered and appropriate action is taken. The Board is kept abreast of progress on Ninety One’s strategy, including material developments which may arise, so they may opine on new developments, including risks.

In terms of key operating decisions, different topics are discussed at meetings per set agendas.

The Executive Management at Ninety One consists of key senior managers and our original founders. The Executive Management represents continuity and stable leadership:

Our Executive Management are supported in their roles by highly skilled and experienced business unit heads that have direct responsibility for activity in their individual markets. Our depth of talent provides us with highly competent and experienced professionals who could take the reins in the event of a leadership change. We have successfully transitioned in times of change – maintaining or even enhancing investment and operational performance and this is testament to the robustness of our structure.

Diversity and inclusion

'Doing the right thing' is part of our cultural identity and underpins everything we do at Ninety One. We know that diversity and inclusion make great business sense. It is also about doing the right thing for our clients, shareholders, our people and the communities in which we operate.

At the core of our values is the respect for the dignity and worth of the individual. Our imperative is to attract and retain the best talent by providing a corporate environment where people from varying backgrounds can develop professionally and build a rewarding career. While there may be minor nuances between the laws of the different countries in which the Company operates, the concepts outlined in our Equality Policy enshrine our global approach to the principles of equality, embracing diversity and doing the right thing.

Underpinned by our Equality Policy, our formal diversity philosophy respects the dignity and worth of the individual and aims to attract and retain the best talent by providing a corporate environment where people from varying backgrounds can develop professionally and build a rewarding career.

We summarize our philosophy to diversity and belonging under 5 pillars:

Diversity commitment | Our commitment is to nurture diversity that reflects society and our clients. We provide equal opportunities in an environment where respect and acceptance are key.

Cultural integration | Our core values, “do the right thing” and “freedom to create,” incorporate our diversity initiatives, giving us a distinctive competitive edge.

Freedom emphasis | Our approach to diversity and belonging emphasizes individual freedom to express, seize opportunities, and realize potential. We do not assume a level playing field.

Shared responsibility | We believe diversity and belonging are collective obligations. Both the organization and individuals are held accountable to counter prejudice, discrimination, and mistreatment.

Culture of inclusion and belonging | We drive value by appreciating differences, creating a culture that fosters individual expression and belonging. This leads to collaboration and superior outcomes for our clients.

Our global diversity principles

Diversity and Inclusion framework

We created a Diversity and Inclusion (D&I) framework to enable change by considering diversity in all our people decisions. Our D&I framework focuses on four key areas:

1. Commitment and accountability of our senior leadership team.

Over the past 11 years the leaders of our business have been committed to creating a more balanced organization with a focus on improvements that enable purposeful, long-term change. We are proactively working towards improving diversity and continually review and measure key diversity statistics, however we are clear that we will create change through concrete actions, rather than targets. This includes our executive management, and our CEO Hendrik du Toit.

We recognize that the diversity in our business continues to reflect the long tenure and stability of our founders, leadership, investment managers and client managers at the firm. We believe our diversity and inclusion principles and framework, detailed previously, will help us to improve diversity across our business.

Since establishment in 1991, our focus on growth, an active ‘risk on’ approach and our underlying philosophy of investing for a world of change and sustainability has contributed markedly to Ninety One playing a significant role in the transformation of South Africa. We believe that this commitment and our stability as an employer, wealth generator and skills developer has been vital in the successful transition to a democratic South Africa. Internally, we have substantially transformed the employee profile of our organization and while we do not have racial employee statistics dating back to 1991, our black staff representation in South Africa has increased from 50% in 2013 to 68% in 2023.

Ninety One releases an annual in accordance with the Equality Act 2010 (Gender Pay Gap Information) Regulations 2017. Ninety One works to create a more balanced organization and reported a positive trend of women progressing through the firm over the past four years.

Ninety One became a signatory to the Women in Finance Charter in 2018 and committed then to achieve a target of 30% women in senior leadership by 2023. Our senior executives' pay was linked to the delivery of this target, which we worked to achieve through concrete actions rather than simplistic hiring quotas. We had 26% female representation in our global senior leadership when we signed up to the Charter in 2018 and were pleased to report that we hit our target ahead of schedule with 31% in 2021 and surpassed it again with 33% in 2022. For our 2023 reporting period we are pleased to report that we now have 36% female senior leadership representation. We are very proud of this achievement and are committed to continuing to build on our progress and are now proactively working on maintaining this target.

Alongside our senior leadership target, we strive for diverse representation on our boards. The Board of Directors for Ninety One is evenly comprised by men and women, and our global Executive Management team is 33% female.

In our annual talent review process leaders are held accountable for managing diversity in their teams and building a diverse pipeline of talent. The data collected during this process is then analysed and presented to our business leaders, with a particular focus on diversity.

2. Enabling change by embedding diversity in all our people decisions

We have made diversity and inclusion a central consideration in all our decision making, especially when it comes to our people. We take a proactive approach to hiring, ensuring balanced and diversified shortlists and interview panels, and that our entry level recruitment creates a diverse pipeline of talent.

We work with universities and support the following cross-industry initiatives to promote and attract diverse talent:

• Investment20/20 - Investment20/20 is focused on creating a more diverse and inclusive investment industry, they are driven to ensure: every individual has the capability to succeed and thrive; aspiring professionals can learn, grow and create value for the firms that seek to attract and retain them; and that workforces are truly reflective of the investors, communities and people we serve. Ninety One has worked with Investment20/20 to hire graduates over the last 5 years.
• The Brokerage - A social mobility charity committed to breaking the corporate model. They believe in equal access to opportunity irrespective of background or race, and talented young people getting the jobs they deserve in a world where their ability and aspiration alone determine their career path. Our UK Client Group have an on-going partnership with The Brokerage and have hosted career events, CV workshops and networking opportunities.
• InterInvest - Ninety One is an active member of InterInvest, an industry network of networks that exists to drive LGBT+ equality and inclusion across the investment industry in the UK and supports similar initiatives globally.

Ninety One offers maternity leave, adoption leave, paternity leave and shared parental leave (‘family leave’) to all its employees, globally. The duration of such leave and value of any statutory pay (or allowance) will depend on the laws of the country in which the employee is located and is subject to the eligibility criteria prescribed by the relevant law.

In addition to any local law requirements regarding family leave and pay (or allowance), Ninety One enhances the statutory family leave and pay (or allowance), on a discretionary basis.

Ninety One treats family leave as a day one right for all its employees, globally.

We place a greater emphasis on productivity than presenteeism and actively encourage flexible working where appropriate.

We are partnered with the 30% Club to offer women across our global business an opportunity to be mentored by an external, seasoned business leader.

We invested in diversity training that was designed to help all our employees become aware of their conscious and unconscious biases. The training was compulsory for all our employees because we believe that everyone shares a responsibility to recognize and remove barriers to inclusion. In this coming year we plan to build on this work, by working closely with our leaders to further explore this topic.

To help build a diverse talent pipeline, diversity is a key consideration in all our leadership development training opportunities.

3. Measuring our progress so we can challenge and change

We monitor key diversity statistics, so we can measure our progress, and use this data to inform our ongoing diversity and inclusion efforts. We share this data with business leaders, including the heads of our investment capabilities, to empower them to effect change.

4. Promoting an inclusive work environment

Our employee networks are essential for creating an environment where everyone can be themselves. These include:

• Ninety One Inspire - A network created for and by women to exchange knowledge and experiences to improve the opportunities for career success.
• Ninety One Belong - A grass roots employee led network to focus on the recruitment, retention and representation of black talent.
• Ninety One Proud - An LGBT+ network to create an internal community and promote an inclusive work
  environment.

19. Do you use an external proxy voting service such as ISS or Glass Lewis? If yes, please specify.

Yes. We use an external proxy research and vote execution service provided by Institutional Shareholder Services (ISS) to produce tailored reports. ISS provide us with a service through which they deliver both their benchmark research and Ninety One’s custom policy research. Ninety One does not outsource the voting decision, as we carry out the decision and execution of the vote in-house using the online voting platform provided by ISS.

These reports include vote recommendations (not instructions) that arise from applying Ninety One’s voting guidelines. The vote decision is then reached by the relevant investment teams in accordance with the investment philosophy, supported by an operational Voting team. Through this rigorous voting process, we can be certain the voting done is in the best interest of our clients.

20. If the answer to the previous question is no, please describe your proxy voting guidelines.

Not applicable

21. If you use an external proxy voting service, do you customize your guidelines for proxy voting? If yes, describe your customized guidelines. If you use the default service guidelines, describe how often and in which situations you deviate from the external proxy voting service recommendations.

Ninety One does not outsource the voting decision: we carry out the decision and execution of the vote inhouse using the online voting platform provided by ISS.

We regularly vote at shareholder meetings throughout the world as a matter of policy and principle. While our engagement framework will vary across investment teams and processes, from an equity perspective proxy voting reflects our proxy voting guidelines, as well as our communications around material sustainability issues throughout the year.

Our '' establish our voting and engagement approach, which applies across all of our equity holdings. It is a comprehensive policy and not only informs how we vote with respect to all resolutions, but also informs both clients and investee companies on the position that we are likely to take with respect to the issues that are placed before us for approval. The proxy voting guidelines rest within our broader stewardship policy framework.

Although our proxy voting guidelines apply globally, we recognize regional differences. In markets where the codes are still evolving and not yet fully aligned with global best practice, we take this into account. In these markets, we aim to engage actively with policymakers, regulators, and stock exchanges, together with other global and local investors, to address more critical potential shortcomings. We understand that some clients may have their own policies, which may differ from our policy. For clients invested in segregated portfolios, we are able to put mechanisms in place to ensure adherence to client-specific voting guidelines.

22. What proportion of the time do you vote with or against management on shareholder resolutions, board appointments, and auditor appointments? What proportion of the time do you vote with or against management on ESG issues? How does this break down for climate, diversity, and remuneration issues?

23. What are your engagement goals? Are these goals outcome/action-based (e.g. decreases in emissions or increases in number of women on the board) or means-based (reporting on emissions or number of women on the board)?

Active ownership is a vital component of Ninety One’s investment management process. Exercising ownership rights, including engagement and proxy voting, is a means through which we can enhance the value of client assets and deliver on the expectations of our clients. Our Stewardship policy and proxy voting guidelines document explains our voting and engagement approach.

Ninety One sees engagement as the preferred means to address material risks and issues that can affect the value of the investments we make on behalf of our clients. Engagements are communications with a clear purpose that seek an identifiable outcome. To identify a need for engagement, Ninety One will assess the materiality of the issue, the potential impact of engagement, both positive and negative, and its ability to exert influence.

Ninety One has three engagement categories:

• Strategic

Firmwide priority engagements to address critical, systemic, or market-wide risks and opportunities.

• General

Entity specific engagements carried out by capabilities as part of their investment research and decision-making. The type and extent of engagement activity will vary depending on the materiality of the issue, and the potential to deliver a positive outcome.

We may collaborate with other investors as part of an engagement strategy if it can contribute to achieving our engagement objectives. Our membership of regional and global organizations facilitates this.

We took part in 488 engagements over 12 months to end March 2024. Many of them were initiated following matters identified in our fundamental investment and voting analysis. Please note that this figure is based on individual interactions and there may be multiple interactions with any one company.

24. What is your policy around the escalation of engagement; how and why might this happen and what is the ultimate tool you might use (e.g. voting against board re-election, etc.)?

We believe that divestment due to an engagement failing to make progress is a last resort. Engagement can be a long-term process, and a company’s willingness to engage and progress made should be taken into consideration, alongside regional and cultural factors.

Typically, before divesting we would want to escalate our engagement actions. This may involve collaboration with other shareholders, stakeholders (NGOs, banks, regulators, etc) or external initiatives, voting at shareholder meetings and proposing our own resolutions. We may also make public statements in the press, although we would not take this course of action until direct engagement with the board and management has failed. Comments to the press will be through nominated spokespeople, recognizing that we won’t always have the opportunity to ensure that our viewpoint is communicated correctly and within context.

However, if the lack of progress on critical issues continues, a disposal of the investment may be necessary.

25. Describe a specific example of your firm’s engagement with a company over the past year, including the outcome and any lessons learned.

WH Group, a Hong Kong listed owner of processed food operations, primarily pork, in China, Europe and the US, has been a longstanding holding in our core Emerging Markets Equity portfolio, which has allowed us ample opportunities to engage in multiple areas including:

• Carbon footprint: Understanding the company’s positioning and encouraging both operational developments e.g. waste to gas, as well as improved reporting disclosures (Scope 1, 2 & 3, and membership of CDP).
• Corporate governance: We have sent a formal letter to the Board outlining areas where we believed the company needed to make meaningful change
• Capital management: Outlining the importance we attached to a progressive dividend policy that looked to smooth out the inherent earnings cyclicality of their operations. It was especially pleasing that this suggestion was soon afterwards adopted by the company and we believe been a key underpinning of the subsequent strong returns from the shares.
• Gender Diversity: Whilst noting the company’s history and the gender employee balance in their operations we outlined the need for improvement, to which the company has started to take steps, albeit tentatively.
• Shareholder rights: While noting conventions in the Hong Kong market, we outlined why we were voting against certain AGM resolutions that could disadvantage external shareholders. On this topic we continue to have ongoing discussions with the company, whilst making clear we will continue to vote against if no changes are made.

Whilst Ninety One’s own sustainability interactions with WH Group continue, we were also delighted in August 2024 to facilitate a call between WH Group and the client who was interested in understanding more about the sustainability initiatives of companies that they hold. It was a wide-ranging and illuminating discussion including the topic of biodiversity. Our client firstly expressed the necessity of addressing this topic at board level, demonstrating long term strategic thinking rather than delegating it to operational management to implement only short term initiatives. There was then a wider discussion about how to take biodiversity beyond just a focus on water usage into other areas where the company’s operations are impactful. On this topic, WH Group explained the initiatives they are undertaking to try to reduce plastic waste within their operations with the concomitant benefits, but also laid out the difficulties they face in doing so given the importance of food hygiene. Overall, this first meeting was helpful for all parties to share insights and create a dialogue. There was a clear expectation that further meetings to update on progress will be held in the future.

Important information

The personal information contained in this document is confidential, and only for the information of the intended recipient.

This communication is for professional investors and financial advisors only. It is not to be distributed to the public or within a country where such distribution would be contrary to applicable law or regulations.

The information may discuss general market activity or industry trends and is not intended to be relied upon as a forecast, research, or investment advice. The economic and market views presented herein reflect Ninety One’s judgment as at the date shown and are subject to change without notice. There is no guarantee that views and opinions expressed will be correct and may not reflect those of Ninety One as a whole, different views may be expressed based on different investment objectives. Although we believe any information obtained from external sources to be reliable, we have not independently verified it, and we cannot guarantee its accuracy or completeness (ESG-related data is still at an early stage with considerable variation in estimates and disclosure across companies. Double counting is inherent in all aggregate carbon data). Ninety One’s internal data may not be audited. Ninety One does not provide legal or tax advice. Prospective investors should consult their tax advisors before making tax-related investment decisions.

Nothing herein should be construed as an offer to enter into any contract, investment advice, a recommendation of any kind, a solicitation of clients, or an offer to invest in any particular fund, product, investment vehicle or derivative. Investment involves risks. Past performance is not indicative of future performance. Any decision to invest in strategies described herein should be made after reviewing the offering document and conducting such investigation as an investor deems necessary and consulting its own legal, accounting and tax advisors in order to make an independent determination of suitability and consequences of such an investment. This material does not purport to be a complete summary of all the risks associated with this Strategy. A description of risks associated with this Strategy can be found in the offering or other disclosure documents. Copies of such documents are available free of charge upon request.

In the US, this communication should only be read by Institutional Investors (Accredited Investors and Qualified Purchasers), Financial Advisors (FINRA-registered Broker Dealers) and, at their exclusive discretion, their eligible clients. It must not be distributed to US Persons apart from the aforementioned recipients. THIS INVESTMENT IS NOT FOR SALE TO US PERSONS EXCEPT ACCREDITED INVESTORS AND QUALIFIED PURCHASERS. Note that returns will be reduced by management fees and that investment advisory fees can be found in Form ADV Part 2A.

In Australia, this material has been prepared by Ninety One Australia Pty Ltd (AFSL 329636) and is intended for wholesale investors only as defined under the Corporations Act 2001 (Cth).

Ninety One Botswana Proprietary Limited, Plot 64289, First floor, Tlokweng Road, Fairgrounds, Gaborone, PO Box 49, Botswana is regulated by the Non-Bank Financial Institutions Regulatory Authority. In Namibia, Ninety One Asset Management Namibia (Pty) Ltd is regulated by the Namibia Financial Institutions Supervisory Authority. In South Africa, Ninety One is an authorised financial services provider.

Except as otherwise authorised, this information may not be shown, copied, transmitted, or otherwise given to any third party without Ninety One’s prior written consent. © 2024 Ninety One. All rights reserved. Issued by Ninety One. March 2025.

Additional information on our investment strategies can be provided on request.

Investment Team

There is no assurance that the persons referenced herein will continue to be involved with investing assets for the Manager, or that other persons not identified herein will become involved at any time without notice. References to specific and periodic team meetings are not guaranteed to be held or fully attended due to reasonable priority driven circumstances and holidays.

Investment Process

Any description or information regarding investment process is provided for illustrative purposes only, may not be fully indicative of any present or future investments and may be changed at the discretion of the manager without notice. References to specific investments, strategies or investment vehicles are for illustrative purposes only and should not be relied upon as a recommendation to purchase or sell such investments or to engage in any particular Strategy. Portfolio data is expected to change and there is no assurance that the actual portfolio will remain as described herein. There is no assurance that the investments presented will be available in the future at the levels presented, with the same characteristics or be available at all. Past performance is no guarantee of future results and has no bearing upon the ability of Manager to construct the illustrative portfolio and implement its investment strategy or investment objective.

Specific Portfolio Names

References to particular investments or strategies are for illustrative purposes only and should not be seen as a buy, sell or hold recommendation. Such references are not a complete list and other positions, strategies, or vehicles may experience results which differ, perhaps materially, from those presented herein due to different investment objectives, guidelines or market conditions. The securities or investment products mentioned in this document may not have been registered in any jurisdiction. More information is available upon request.

Indices

Indices are shown for illustrative purposes only, are unmanaged and do not take into account market conditions or the costs associated with investing. Further, the manager’s strategy may deploy investment techniques and instruments not used to generate Index performance. For this reason, the performance of the manager and the Indices are not directly comparable.

MSCI data is sourced from MSCI Inc. MSCI makes no express or implied warranties or representations and shall have no liability whatsoever with respect to any MSCI data contained herein. The MSCI data may not be further redistributed or used as a basis for other indices or any securities or financial products. This report is not approved, endorsed, reviewed or produced by MSCI. None of the MSCI data is intended to constitute investment advice or a recommendation to make (or refrain from making) any kind of investment decision and may not be relied on as such.

FTSE data is sourced from FTSE International Limited (‘FTSE’) © FTSE 2024. Please note a disclaimer applies to FTSE data and can be found at