BNY MELLON ENTERPRISE ESG 57 RESPONSIBLE BUSINESS A UK-based global equity investment management firm AUM: $106 billion (as of 12/31/21) RI Approach: Walter Scott believes that the companies that make the best long-term investments typically adhere to the highest standards of integrity, sustainability and governance. Walter Scott integrates analysis of these factors into its investment process, while acting as trusted stewards of clients’ assets. Its approach to responsible investing and stewardship is focused on three key areas: Integrated Research & Analysis, Engagement, and Proxy Voting. A PRI Signatory since 2017. Progress in 2021 • Awarded signatory status to the new voluntary UK Stewardship Code by the Financial Reporting Council • Appointed a Head of Investment Operations and Sustainability • Established the role of Investment Manager - Responsible Investment, with responsibility for driving RI analysis and engagement • Established an Investment Stewardship Committee with responsibility for the governance and oversight of engagement and proxy voting • Deepened the integration of sustainability analysis into the investment process • Included discussion of sustainability issues in a majority of all owned company engagements DEFINING RESPONSIBLE INVESTMENT Despite acknowledgement of the importance of and interest in RI globally, there remains a lack of industry standardized terminology, with many terms used interchangeably. We define RI as investing for a better future and for better returns for all, regardless of the approach taken. To provide clarity on how we approach RI at BNY Mellon IM, we have laid out how we define certain RI-related terminology used by the investment management industry in a Glossary in this report. RESPONSIBLE INVESTMENT STYLES Responsible Investment covers a spectrum of investing styles, including ESG integration, exclusionary screening, best-in-class screening, sustainable investing, impact investing and philanthropy. For all investment styles, stewardship of clients’ assets is a key component, as is ongoing development of reporting ESG portfolio assessments to clients. While the majority of our RI products or solutions integrate ESG considerations, among a range of other factors, into the financial analysis and/or investment decisions, they do not have any objective or binding intent to be responsible. In addition, our firms offer a growing suite of funds and accounts that do have a binding and explicit intent to be responsible through either a rules-based approach to universe selection (negative and best-in-class screening) or an environmental and/or social objective or theme (sustainable/thematic investing and impact investing). In 2021 we expanded our range of offerings with a stated intent to be responsible through Newton, Insight and Alcentra. By the end of 2021, BNY Mellon IM firms offered 27 such funds and 20 separate accounts, including 10 in EMEA and seven in North America. We intend to continue this growth in 2022. Guided by a global head of Responsible Strategy hired in 2021, we are implementing a Responsible Investment program and creating a unified strategy even as each investment firm maintains autonomy over its individual approach. Our goal is to offer solutions across the spectrum of RI while anticipating both our clients’ needs and upcoming regulatory requirements globally. Recognizing that management and disclosure of ESG data is a key area of focus, we aim to develop enhanced reporting on environmental and social issues for our