Principles for responsible investment

Investment decisions are made based on analyses of markets, industries and companies. Selected strategies target creating excess returns relative to selected benchmarks. Active investment strategies include identifying the risks and opportunities arising from factors related to environmental, social and governance (ESG) matters, including climate risk. The portfolio manager’s assessment of ESG factors, in addition to other factors, provides a comprehensive picture of risk and opportunities in each investment case.

The principles for responsible investment apply to all funds, portfolios, asset classes and investment styles managed by Equinor Asset Management.

The six Principles are:

• We will incorporate ESG issues into investment analysis and decision-making processes.
• We will be active owners and incorporate ESG issues into our ownership policies and practices.
• We will seek appropriate disclosure on ESG issues by the entities in which we invest.
• We will promote acceptance and implementation of the Principles within the investment industry.
• We will work together to enhance our effectiveness in implementing the Principles.
• We will each report on our activities and progress towards implementing the Principles

PRI has prepared a framework for responsible investment, which is divided into three main areas; investment decisions, active ownership and policy engagement. Equinor Asset Management’s implementation of responsible investment is based on this framework:

Exclusions

Companies that Equinor Asset Management's funds and clients invest in shall comply with international laws, norms and conventions. We have therefore chosen to exclude certain companies from our investment universe. Our ethically motivated guidelines for exclusion corresponds with the exclusion criteria in the regulation "Guidelines for observation and exclusion from the Government Pension Fund Global". The exclusions are based on either unwanted behaviour/conduct or type of products produced.

Conduct-based exclusions:

• Companies involved in gross or systematic human rights violations, such as murder, torture, deprivation of liberty, forced labour, the worst forms of child labour and other exploitation of children.
• Companies that contribute to serious violations of individual’s rights in war or conflict situations.
• Companies involved in serious environmental damage.
• Companies that are responsible for acts or omissions that on an aggregate company level lead to unacceptable greenhouse gas emissions.
• Companies involved in gross corruption or other serious financial crime.
• Companies involved in other particularly serious violations of basic ethical norms.

Product-based exclusions:

• Companies that themselves or through entities they control, produce weapons that, in normal use, violate basic humanitarian principles.
• Companies that are largely involved in the extraction or use of thermal coal.
• Companies that produce tobacco.
• Companies that produce cannabis for recreational use.

The guidelines are integrated into our portfolios by banning investments in companies that Norges Bank has excluded from the Government Pension Fund Global (SPU)’s investment universe, based on «Guidelines for observation and exclusion from the Government Pension Fund Global». Hence, an overview of companies excluded from Equinor Asset Management's investment universe can be found on NBIM’s website (www.nbim.no) with the heading "Observation and exclusion of companies".

For companies that are not included in the regulation "Mandate for the management of the Government Pension Fund Global", decisions to exclude companies is made by the managing director based on assessments in Equinor Asset Management's ESG forum. Assessments from external sources shall also be included in the considerations.

ESG integration in active investment decisions

Responsible investment is integrated into Equinor Asset Management's investment strategies. When a portfolio manager takes active risk, the objective is to identify investment opportunities that, over time, provide the best possible excess return relative to the active risk taken. Consequently, risks related to ESG factors are considered, as well as the companies' principal adverse impact measured by selected sustainability indicators, including violations of the UN Global Compact's principles.

In order to give the portfolio managers enough knowledge to make relevant risk assessments, Equinor Asset Management has access to company information from many sources. Knowledge is essential to uncover conditions that might have an impact on the company's long-term value creation. The portfolio managers' analyses are based on information from the companies, third party vendors, media and through active participation in discussions with market participants and other stakeholders.

External fund managers

In its exercise of investment services, Equinor Asset Management may invest in securities funds managed by other fund managers. External fund managers shall have the same, or equivalent, guidelines for responsible management as Equinor, including criteria for exclusion, as well as being a PRI signatory.

Index funds and listed securities funds (ETFs) containing holdings in companies excluded by Equinor, can only be used to a limited extent to achieve exposure, risk management and efficient portfolio management. However, such investments can only be made if excluded companies constitutes a very small part of the fund, and only in those cases where there are no other good investment alternatives.

Active ownership

Equinor Asset Management believes that exercising shareholder rights on behalf of our clients and unit holders will promote sustainable value development. Active ownership may be exercised in two ways: by using the voting rights in shareholder meetings, or through direct dialogue (engagement) with the management and board members of the relevant companies.

Both ways can be effective when it comes to addressing issues related to ESG. Especially voting, in line with other investors, can contribute to better corporate governance and safeguarding shareholder value. Equinor Asset Management invests in more than 1,600 companies on behalf of our clients and funds and will use governance services and recommendations from external sources, and cooperate with others, to ensure an effective follow-up of the ownerships.

Use of voting rights

In addition to our expectations to the companies, Equinor Asset Management's voting guidelines is based on best practice published by the Norwegian Code of Practice for Corporate Governance (NUES). NUES is aligned with the OECD Guidelines for Multinational Companies, as well as the OECD's Corporate Governance Principles.

The framework for the use of voting rights for funds managed by Equinor Asset Management is set out in the Regulations to the Norwegian Securities Funds Act section 2-24, and in the Industry recommendation developed by the Norwegian Fund and Asset Management Association (VFF).

The responsibility for executing ownership rights and corporate governance on behalf of Equinor Asset Management's funds lies with the Board of Directors. However, the daily management is by proxy delegated to the managing director. The exercise of ownership rights and corporate governance shall be done in accordance with the voting guidelines adopted by the Board of Directors.

Equinor Asset Management reports the use of ownership rights to the Board of Directors, which evaluates the execution of ownership rights and corporate governance on an annual basis.

Discretionary clients can also authorise Equinor Asset Management to exercise ownership rights. The power of attorney, guidelines and reporting requirements are included in the individual investment management agreement with the client.

Equinor Asset Management has chosen to use an external service provider, Institutional Shareholder Services (ISS), in connection with voting at general meetings. ISS provides a platform for proxy voting, and sends notice of general meetings, provides comprehensive information about the companies and agenda points to be voted on, as well as recommendations for voting. The recommendations are based on recognized principles for good corporate governance.

The voting guidelines for Equinor Asset Management's fund are based on the principles in ISS's Benchmark Policy Recommendations. The fund's voting guidelines provides high-level principles, while ISS's guidelines are very detailed and adapted to relevant markets. https://www.issgovernance.com/policy-gateway/upcoming-policies/

The voting is performed automatically by ISS based on these guidelines. However, the voting is monitored on an ongoing basis by following up selected companies of interest manually.

Equinor Asset Management reviews the contractual relationship with ISS on an annual basis, including the quality and effectiveness of the services offered.

Engagement

The decision to engage with selected companies is based on an overall assessment of the importance of specific cases, the size of the investment and the extent to which positive changes are realistic to achieve. Dialogue with selected companies will typically be done in cooperation with other investors.

Reporting and control

The portfolio managers are responsible for compliance with Equinor Asset Management's principles for responsible investment in execution of the investment process and investment decisions. The portfolio managers are responsible for ongoing monitoring of the companies in the portfolios.

In order to ensure good and open communication to our unit holders and other stakeholders, Equinor Asset Management shall:

• Publish how ESG risk considerations are taken into account in the investment process for the funds, as well as principal adverse impact.
• Publish the funds’ voting on the fund managers website.
• Update unit holders and other clients on how the tools in the framework are used to contribute to sustainable development and long-term value creation. Reporting through our website and/or annual reports.

The company's compliance function is responsible for monitoring compliance with the guidelines and controls, including the annual report to the Board of Directors and renewal of power of attorneys to the managing director.

Approved by the Board of Directors of Equinor Asset Management AS, 12. December 2022