UKRF Implementation Statement
On an annual basis, the Trustee is required to make publicly available online a statement (the Implementation Statement) covering both the Defined Contribution (DC) and Defined Benefit (DB) sections of the Barclays Bank UK Retirement Fund ("UKRF", "the Fund"). This Implementation Statement covers the Fund year from 1 October 2021 to 30 September 2022, and sets out the following activity for the year:
- Any review of the Statement of Investment Principles (SIP) including an explanation of any changes to the SIP;
- How, and the extent to which, in the opinion of the Trustee, the SIP has been followed; and
- The voting behaviour by, or on behalf of, the Trustee (including the most significant votes cast by the Trustee or on its behalf) and the use of the services of a proxy voter.
Review of the SIP over the year
The most recently updated SIP took effect from 1 October 2021. The Trustee reviews the SIP on an annual basis and after a significant change in investment strategy. There were no changes made to the SIP as a result of the review completed in the year. The review is conducted in consultation with the principal employer, Barclays Bank PLC, and with the support of the Trustee’s investment advisors.
How the Trustee has implemented its investment policies over the year
The Trustee acted in full accordance with its own investment principles and implemented the policies set out in the SIP over the year to 30 September 2022. A summary of the year’s key activities is set out below:
The Trustee exercised its investment responsibilities over the year as part of its duty to act in members’ best interests. Oak Pension Asset Management Ltd (“OPAM”) operates under formal delegation from the Trustee, in line with parameters agreed by the Trustee. OPAM is responsible for the management of the UKRF asset portfolio and the implementation of the Trustee strategy, including the appointment, supervision and management of the Fund’s underlying investment managers and the implementation and monitoring of the Fund’s investment policy. The terms of the relationship between the Trustee and OPAM are set out in an Investment Advisory and Management Agreement (“IAMA”) which documents the Trustee’s expectations of OPAM, alongside Investment Guidelines under which OPAM is required to operate. There were no material changes in the year to the investment governance framework through which the Trustee makes investment-related decisions.
The SIP is owned by the Trustee with the detailed implementation and monitoring of the DB investment policy formally delegated to OPAM.
The performance of the DB assets, against the objectives set out in the SIP, is monitored by the Trustee with support from its strategic investment adviser and OPAM, with performance calculations provided by J.P. Morgan, the Fund’s DB custodian.
The funding level of the DB section improved during the year. The portfolio remains well diversified with an appropriate level of investment risk and expected return, with key financial risks (compared to liabilities) being mostly mitigated through hedging. The Trustee has closely monitored performance against the Fund’s investment objectives throughout the year using a monitoring framework called the Pensions Risk Management Framework (“PRMF”). This sets the investment objectives and acts as a reference point for decision making. The Fund is currently ahead of plan against its strategic funding objectives and the investment strategy has remained robust throughout the financial year. Actions were taken by OPAM throughout the year to proactively maintain cash buffers and during September 2022 to maintain a strong collateral position in response to the market activity impacting on Liability Driven Investment ("LDI"). Alongside this, all benefits were paid as they fell due in the year.
To understand the potential impact of different market environments and climate scenarios on the UKRF, the Trustee, supported by its strategic investment adviser and OPAM, undertook stress test and scenario analysis. The Trustee considered possible mitigation strategies should the chosen scenarios materialise and decided that for the purposes of prudent risk management, the stress test and scenario analysis will be included within the Fund’s regular reporting, including the PRMF, for monitoring on an ongoing basis.
The Trustee’s primary investment objective is to make available, at a reasonable cost, a number of investment options that provide members with access to a range of different asset classes that differ in their level of investment risk and liquidity. The Trustee operates a Lifestyle Fund range (DC default option) and a range of self-select funds.
The Trustee concluded the last triennial review of the Fund’s DC investment options in September 2019. The latest triennial review commenced in Q3 2022 and the Trustee continues to review the outputs from this exercise.
In December 2020 the Trustee implemented changes to the UKRF Diversified Growth Fund ("DGF"), which is a core component of the Lifestyle Fund range, to further align the investments with the Trustee’s environmental, social and governance (ESG) principles. As a further evolution, the Trustee implemented the following over the course of the Fund year:
- In line with Trustee’s ambition to halve UKRF’s greenhouse gas emissions by 2030 and to be net zero carbon by 2050, the Equity portfolios within the UKRF DGF Fund were transitioned to Climate Transition Benchmark ("CTB") guidelines in Q2 2022. The CTB methodology introduces a forward-looking commitment to decarbonise the portfolios by 7% year-on-year.
- The CTB guidelines also mandate that portfolios should have an increased allocation to companies that set science-backed emissions reduction targets and companies with higher green revenues relative to the benchmark.
The changes were assessed prior to implementation and were not considered to negatively impact upon performance or costs of the UKRF DGF, whilst also providing a positive step towards alignment with the Trustee’s net zero ambition.
The Trustee regularly reviews the performance, structure and operation of all funds provided through the DC Section and this includes a formal annual investment and operational due diligence assessment of the funds. Overall, the Trustee is comfortable that the available funds remain appropriate for members to invest in, and also that the policies in place to mitigate the material risks members face were followed and remain adequate. Ongoing monitoring and review of DC funds, including the charges and transaction costs, remains a priority for the Trustee, not only from a shorter-term perspective but also regarding the strategic, longer-term appropriateness and consistency of such funds for members’ DC pension savings.
Annually the Trustee also analyses the charges (Total Expense Ratios) and transaction costs levied by the investment managers, which were benchmarked by the Trustee’s DC investment advisers. Such costs are reported to members in the Chair’s Statement on DC governance (see page 68 of linked annual report). Based on external advice and input from OPAM, the Chair confirms that the charges and transaction costs applied to the DC Section’s range of investment options are reasonable and competitive, taking into account the size and investment strategy of the UKRF DC Section.
The Trustee has a standalone Responsible Investment (“RI”) policy, which describes the Trustee’s approach to RI in the context of managing the UKRF, outlining the guiding principles the Trustee has adopted and the core activities undertaken. An abridged version of the RI policy is included in the SIP. The full version of the RI policy can be found here.
The Trustee believes there is evidence that sustainable business practices lead to better risk-adjusted returns and outcomes in the long-term and so considers ESG factors and their potential implications for the UKRF throughout its investment process and within the Fund’s overall RI approach.
The Trustee sees climate change as a key financial risk affecting its investment asset portfolio and climate change is therefore the subject of specific risk management, measurement, stewardship, and collaborative efforts as part of the UKRF’s wider investment and RI activities. Further details of the Trustee’s governance and approach to addressing climate change risks faced by the UKRF can be found in the UKRF’s 2022 Task Force on Climate-related Financial Disclosures (“TCFD”) Report which will be published by 30 April 2023 here. This the UKRF’s first mandatory TCFD statement and is part of our initial work on climate change, which has included in the year assessing appropriate ESG metrics and targets that will help facilitate improved measurement and management of climate-related risks.
The Trustee requires its appointed investment managers to be cognisant of ESG-related financial risks and opportunities. The Trustee is supported by OPAM in its engagement with managers, who also perform ongoing investment and operational due diligence and regular monitoring. This ensures that the Fund’s appointed managers incorporate ESG risks and opportunities into the investment process.
The Trustee continues to integrate RI considerations within the Fund’s strategic and day-to-day management processes and decision-making, aiming for improved risk-adjusted returns across both the DB and DC sections. Over the year, the Trustee supported by OPAM and its relevant advisors implemented activities that are consistent with its RI policy. These activities included:
- Continued to perform, monitor and review ESG analytics on the Fund’s public equity and fixed income portfolios. This helps OPAM better engage with the Fund’s investment managers on ESG factors on the Trustee’s behalf. Further details on the climate metrics are provided in the TCFD report available online.
- Agreed climate investment guidelines for a selection of the Fund’s fixed income managers (as at 30 September 2022 c.19% of the UKRF assets), representing a significant step for the UKRF regarding its net zero ambition. Guidelines covered the key areas: year on year emissions de-carbonisation; selective coal exclusions; stewardship/engagement; issuers’ science based transition pathway monitoring; investments in Climate solutions; and targeting equal or higher Social and Governance scores for the portfolios.
- Participated in the first two syndications of Green Gilts issued by the UK Government in September and October 2021. The UKRF accumulated a total of c£37m across the two green gilts in the primary market. Green Gilts are intended to positively contribute to the UK Government’s Green Financing strategy, helping to finance the transition to a green economy, tackling environmental challenges and creating green jobs across the UK. This is consistent with the Trustee’s own RI objectives.
- Approved a further commitment of £200m to infrastructure projects which included social debt exposure (e.g. provision of affordable social housing), renewable energy generation (e.g. solar, wind, hydro), and energy efficiency. This commitment will be invested in projects in the coming years and will further contribute towards the UKRF’s RI goals.
- As outlined above in line with Trustee’s net zero ambition, transitioned the equity allocations within the UKRF DGF to meet the minimum standards of the European Union Climate Transition Benchmark (“CTB”) guidelines in Q2 2022. The CTB methodology introduced a forward-looking commitment to decarbonise the portfolio by 7% year-on-year.
The Trustee will continue updating and evolving its approach to investing responsibly.
The Trustee recognises its position as an asset owner with ultimate responsibility to its members and beneficiaries, accepting that effective stewardship can help protect and enhance the long-term value of its investments to the ultimate benefit of these beneficiaries.
The Trustee initially signed up to the UK Stewardship Code in 2011. The Code sets out a clear benchmark for stewardship as the responsible allocation, management, and oversight of capital to create long-term sustainable benefits for the economy, the environment and society. The Trustee also expects its investment managers to adhere to the principles within the UK Stewardship Code.
In 2022, the UKRF retained its signatory status to the substantially revised and strengthened UK Stewardship Code 2020. Here is the UKRF’s full 2021 UK Stewardship Code report. This provides additional detail on the stewardship and engagement activity carried out by the Trustee.
For the DB assets, the Trustee has appointed EOS at Federated Hermes (“EOS”) as a specialist engagement provider and proxy voter to maximise the Trustee’s influence as an active owner. EOS performs targeted engagement with companies on behalf of a number of asset owners, including the UKRF.
As part of its ongoing process, EOS identifies companies in which its clients, including the UKRF, are invested and will conduct a programme of engagement where EOS considers it both desirable and feasible to influence change. This includes opportunities pertaining to corporate governance and the management of ESG issues, including the companies' capital structure, with a view to improving long-term performance and outcomes.
The Trustee regularly monitors the effectiveness of EOS’s activities and, where appropriate, considers how engagement could inform investment decisions. As an example, the Trustee reviewed EOS’s activities for consistency with the Trustee’s net zero carbon ambition. OPAM monitors material stewardship activity by EOS pertaining to the UKRF’s investments. EOS reports to the UKRF Trustee Board on an annual basis.
The majority of funds provided to DC members are pooled funds, managed by BlackRock and Jupiter and the Trustee has therefore delegated the stewardship, engagement and voting activities to the pooled fund managers.
For the UKRF DGF, assets are invested through a combination of pooled funds and directly held investments. As the investment manager of the DGF, BlackRock is responsible for the stewardship, voting and engagement activities for all holdings in the DGF. Through its ongoing monitoring and due diligence on the underlying funds, the Trustee is comfortable the actions of the pooled fund managers are aligned with the Fund’s policy on stewardship and engagement. There have been no changes to the stewardship process for the DC section during the year.
Results of the voting activity in respect of both the DB and DC sections are set out in the Voting and Engagement Data section. This section includes information related to the most significant votes by considering items including the following:
Potential impact on financial outcome:This would include votes which the manager considers might have a material impact on future company performance, for example approval of a merger or a requirement to publish a business strategy that is aligned with the Paris Agreement on climate change.
Stewardship outcome:This could include any decision which may reduce the investor voice (e.g. around shareholder rights), such as a debt for equity swap, management buyout of a significant share of equity or a downgrading of voting rights.
The size of the holding in the mandate.
If the vote was high-profile/controversial:This could be judged using any or all of the following: a significant level of opposition from investors to the company resolution; a significant level of support for an investor resolution; level of media interest; level of political or regulatory interest; level of industry debate.
Conflicts of interest policy
The Trustee has a formal conflicts of interest policy which sets out its principles and procedures for identifying, assessing, and managing actual and potential conflicts of interest, including third party advisers, in order to minimise the possibility of such conflicts arising. Specifically, in relation to Fund investments, the Trustee has a general policy of no direct self-investment in Barclays Bank PLC or associated companies. This is reviewed annually and covers the circumstances in which conflicts might arise in line with the relevant guidance and requirements of Pensions Regulator, the Pensions Act 1995 and the Companies Act 2006.
OPAM maintains a separate policy on managing conflicts of interest. This includes a review of each investment manager’s conflicts of interest policy which is undertaken as part of the managers’ operational due diligence and review process. EOS has a publicly available Stewardship Conflicts of Interest Policy, which is reviewed by OPAM on behalf of the Trustee.
There were no breaches of the Trustee’s, OPAM’s or EOS’s conflicts of interest policies during the financial year.
The Trustee delegates the management of its relationships with third-party investment managers to OPAM with the Asset Manager policy covering both DB and DC investment arrangements. OPAM regularly monitors all UKRF managers through its investment monitoring process.
The terms of the long-term relationship between the Trustee and OPAM are set out in a separate IAMA. This documents the Trustee's expectations of OPAM, alongside the investment guidelines under which OPAM is required to operate. The investment guidelines are based on a combination of the policies set out in the SIP, the Trustee's PRMF and RI Policy. The investment guidelines are updated following any changes to one of these documents, ensuring OPAM acts in the best long-term interests of the UKRF at all times.
The Trustee remains comfortable that the IAMA is effective and, over the year, continued to monitor OPAM using a framework-based approach, as well as meeting with OPAM on a regular basis. For the DB sections, based on backdated analysis used within this framework, the UKRF’s return generated over the year has exceeded the return required to achieve the UKRF’s primary funding objective.
The IAMA sets out the Trustee’s expectation with regard to OPAM’s monitoring of fees, portfolio turnover costs and turnover range, which are reviewed by OPAM annually. In assessing the appropriateness of the portfolio turnover costs at an individual manager level, OPAM will have regard to the actual portfolio turnover and how this compares with the expected turnover range for that mandate. In addition, the Trustee reviews the costs incurred in managing the Fund's assets annually. The Trustee and OPAM are satisfied that the costs incurred in managing the Fund’s assets and those associated with portfolio turnover during the reporting year were appropriate, taking into account the size and investment strategy of the UKRF.
The Trustee has a general policy of not investing directly in shares issued by the employer, Barclays Bank PLC, or associated companies. However, the Trustee accepts indirect exposure, for example as a result of investment in index-tracking funds.
The Trustee’s employer related investment is monitored regularly by OPAM and no breaches of this policy have been reported over the year.
As part of its overarching DB investment policy, the Trustee has considered the investment return and associated risk that each asset class is expected to provide. Consistent with investment management agreements and delegations, OPAM performed its role in respect of the day-to-day selection of assets to maintain the Fund’s stated expected return target. The Fund’s expected return, relative to the required return on both the primary and long-term funding objective, is monitored on a monthly basis.
The Trustee reviews the performance of all funds within the DC section with reference to each fund’s expected return and stated objectives. For the UKRF DGF, the target is to outperform short-term cash (i.e. deposit) rates by 4.5% pa over the long term. The self-select options include return-seeking and liability-matching funds, allowing members to target an appropriate expected return and risk profile for their requirements.
Voting and engagement data
|Voting data||EOS at Federated Hermes - Stewardship Provider|
|Structure||EOS at Federated HermesSegregated|
|Relevant Period||EOS at Federated Hermes1 Oct 2021 – 30 Sep 2022|
|Ability to influence voting behaviour of manager||EOS at Federated HermesThe segregated mandates allow the Trustee to engage with the manager and influence their voting behaviour.|
|Number of company meetings the manager was eligible to vote at over the year||EOS at Federated Hermes1,311|
|Number of resolutions the manager was eligible to vote on over the year||EOS at Federated Hermes18,776|
|Percentage of resolutions the manager voted on||EOS at Federated Hermes94.3%|
|Percentage of resolutions the manager abstained from||EOS at Federated Hermest0.1%|
|Percentage of resolutions voted with management, as a percentage of the total number of resolutions voted on||EOS at Federated Hermes84.4%|
|Percentage of resolutions voted against management, as a percentage of the total number of resolutions voted on||EOS at Federated Hermes15.6%|
|Percentage of resolutions voted contrary to the recommendation of the proxy adviser||EOS at Federated Hermes10.2%|
|Vote 1||Vote 2||Vote 3|
|Company name||Vote 1Nike||Vote 2Royal Bank of Canada||Vote 3American Express|
|Date of vote||Vote 16 Oct 2021||Vote 227 Apr 2022||Vote 33 May 2022|
|Summary of the resolution||Vote 1Report on Diversity and Inclusion Efforts||Vote 2Adopt an Annual Advisory Vote Policy on the Bank's Environmental and Climate Change Action Plan and Objectives||Vote 3Require Independent Board Chair|
|How the manager voted||Vote 1For||Vote 2For||Vote 3For|
|If the vote was against management, did the manager communicate their intent to the company ahead of the vote?||Vote 1Yes||Vote 2Yes||Vote 3Yes|
|Rationale for the voting decision||Vote 1Shareholder proposal promotes transparency||Vote 2Shareholder proposal promotes better management of ESG opportunities and risks||Vote 3Shareholder proposal promotes appropriate accountability or incentivisation|
|Outcome of the vote||Vote 1Fail||Vote 2Fail||Vote 3Fail|
|Implications of the outcome||Vote 1The resolution failed but with significant shareholder support (35.6%)||Vote 2The resolution failed but with significant shareholder support (21.6%)||Vote 3The resolution failed but with increased support from a year earlier|
|Criteria on which the vote is considered “significant”||Vote 1Large and significant company, ESG related shareholder proposal, voted against management.||Vote 2Large and significant company, ESG related shareholder proposal, voted against management.||Vote 3Large and significant company, ESG related shareholder proposal, voted against management.|
Voting and engagement data
|Engagement data - DB Section||EOS at Federated Hermes - Stewardship Provider|
|Does the manager perform engagement on behalf of the holdings of the fund?||EOS at Federated HermesYes|
|Has the manager engaged with companies to influence them in relation to ESG factors in the year?||EOS at Federated HermesYes|
|Number of engagements undertaken on behalf of the holdings in this fund in the year||EOS at Federated Hermes2,389 (engagements defined as a count of objectives or issues with a linked action over the reported period)|
|Number of engagements undertaken at a firm level in the year||EOS at Federated Hermes4,045|
|Examples of engagements undertaken with holdings in the fund||EOS at Federated HermesEOS engaged with Berkshire Hathaway on climate-related risks. Also engaged with Volvo on TCFD-aligned reporting.|
|Fund name||Manager 1UKRF Diversified Growth Fund||Manager 1UKRF Global (ex-UK) Equity Index Fund||Manager 1UKRF Emerging Markets Equity Index Fund||Manager 1UKRF UK Equity Index Fund||Manager 2UKRF Sustainable Equity Fund|
|Structure||Manager 1Segregated||Manager 1Pooled fund||Manager 1Pooled fund||Manager 1Pooled fund||Manager 2Pooled fund|
|Relevant Period||Manager 11 October 2021 – 30 September 2022||Manager 11 October 2021 – 30 September 2022||Manager 11 October 2021 – 30 September 2022||Manager 11 October 2021 – 30 September 2022||Manager 21 October 2021 – 30 September 2022|
|Ability to influence voting behaviour of manager||Manager 1The segregated mandate allows the Trustee to engage with the manager and influence their voting behaviour||Manager 1The pooled fund structure means that there is limited scope for the Trustee to influence the manager’s voting behaviour||Manager 1The pooled fund structure means that there is limited scope for the Trustee to influence the manager’s voting behaviour||Manager 1The pooled fund structure means that there is limited scope for the Trustee to influence the manager’s voting behaviour||Manager 2The pooled fund structure means that there is limited scope for the Trustee to influence the manager’s voting behaviour|
|Number of company meetings the manager was eligible to vote at over the year||Manager 13,071||Manager 12,216||Manager 12,746||Manager 11,096||Manager 258|
|Number of resolutions the manager was eligible to vote on over the year||Manager 134,285||Manager 126,666||Manager 123,622||Manager 114,795||Manager 2781|
|Percentage of resolutions the manager voted on||Manager 189.68%||Manager 191.47%||Manager 198.10%||Manager 196.01%||Manager 2100.0%|
|Percentage of resolutions the manager abstained from||Manager 10.59%||Manager 10.53%||Manager 13.93%||Manager 11.76%||Manager 20.77%|
|Percentage of resolutions voted with management, as a percentage of the total number of resolutions voted on||Manager 193.87%||Manager 192.9%||Manager 188.32%||Manager 194.99%||Manager 297.31%|
|Percentage of resolutions voted against management, as a percentage of the total number of resolutions voted on||Manager 16.13%||Manager 17.10%||Manager 111.68%||Manager 15.05%||Manager 22.69%|
|Percentage of resolutions voted contrary to the recommendation of the proxy advisor||Manager 10.25%||Manager 10.46%||Manager 11.03%||Manager 10.03%||Manager 21.02%|
DC significant votes
|Engagement topics||Vote 1||Vote 2||Vote 3|
|Company name||Vote 1Novozymes A/S||Vote 2Borregaard ASA||Vote 3A.O. Smith Corporation|
|Date of vote||Vote 17 March 2022||Vote 231 March 2022||Vote 311 April 2022|
|Approximate size of fund's holding as at the date of the vote (as % of portfolio)||Vote 11.33%||Vote 22.86%||Vote 32.09%|
|Summary of the resolution||Vote 1Re-elect Jorgen Buhl Rasmussen (Chair) as Director||Vote 2Elect Directors (Voting for All items 7a.1-7a.5 Bundled), Re-elect Helge Aasen as Director, Re-elect Helge Aasen as Board Chair||Vote 3Advisory Vote to Ratify Named Executive Officers' Compensation|
|How the manager voted||Vote 1Abstain||Vote 2For||Vote 3Against|
|If the vote was against management, did the manager communicate their intent to the company ahead of the vote?||Vote 1No||Vote 2N/A||Vote 3No|
|Rationale for the voting decision||Vote 1As Chair of the remuneration and nomination committee, gender diversity on the board is under his remit and should be improved. The company adopted new diversity targets in its 2021 annual report, Jupiter will be monitoring board appointments next year.||Vote 2Decided to vote in favour of items 7a, 7a.1 and 7b. Jupiter spoke with the nomination committee ahead of the AGM vote and felt a vote against Helge was not warranted at this at this stage. The concerns around him being overboard still linger, but can be managed, and Jupiter are monitoring the tenure of his CEO position, with the company looking for a replacement.||Vote 3Jupiter voted against the executive compensation because only 1/3 of the long-term incentive awards are tied to challenging performance conditions. Jupiter don’t consider the 5% return on equity hurdle for the restricted stock units to be stretching at all. Furthermore the options vest over a short time period of less than three years, which doesn’t feel in the spirit of a long-term incentive, and it is not clear why the return on investment capital/weighted average cost of capital tested aspect vests in cash rather than equity when Jupiter would like to see the exec chair own more shares.|
|Outcome of the vote||Vote 1Pass||Vote 2Pass||Vote 3Pass|
|Implications of the outcome||Vote 1Jupiter remain invested and continue to monitor best practice matters at the company.||Vote 2Jupiter remain invested and will continue to monitor the tenure of his CEO position.||Vote 3The resolution passed and Jupiter remain invested in the company. Jupiter will continue to monitor remuneration practices at the company.|
|Criteria on which the vote is considered “significant”||Vote 1Potential impact on financial outcome||Vote 2Potential impact on financial outcome||Vote 3Potential impact on financial outcome|
|Engagement topics||Vote 1||Vote 2||Vote 3|
|Company name||Vote 1Meta Platforms Inc.||Vote 2Glencore Plc.||Vote 3The Home Depot Inc.|
|Date of vote||Vote 125 May 2022||Vote 228 April 2022||Vote 319 May 2022|
|Approximate size of fund's holding as at the date of the vote (as % of portfolio)||Vote 1The data is not available at the time of reporting||Vote 2The data is not available at the time of reporting||Vote 3The data is not available at the time of reporting|
|Summary of the resolution||Vote 1Approve Recapitalization Plan for all Stock to Have One-vote per Share||Vote 2Approve Climate Progress Report||Vote 3Oversee and Report a Racial Equity Audit|
|How the manager voted||Vote 1For||Vote 2For||Vote 3For|
|If the vote was against management, did the manager communicate their intent to the company ahead of the vote?||Vote 1BlackRock endeavour to communicate to companies when we intend to vote against management, either before or just after casting votes in advance of the shareholder meeting||Vote 2BlackRock endeavour to communicate to companies when we intend to vote against management, either before or just after casting votes in advance of the shareholder meeting||Vote 3BlackRock endeavour to communicate to companies when we intend to vote against management, either before or just after casting votes in advance of the shareholder meeting|
|Rationale for the voting decision||Vote 1Effective voting rights are a fundamental right of share ownership. We believe that “one vote for one share” is a guiding principle that supports effective corporate governance.||Vote 2BlackRock supported this proposal in recognition of the company’s disclosed plan to manage climate-related risks and opportunities and the company’s progress against this plan.||Vote 3BlackRock supported this shareholder proposal because, in BlackRock’s view, shareholders would benefit from a third party assessment of Home Depot’s diversity, equity and inclusion (DEI) practices given their large and diverse workforce and extensive presence in communities.|
|Outcome of the vote||Vote 1Not approved||Vote 2Approved||Vote 3Approved|
|Criteria on which the vote is considered “significant”||Vote 1Impact on potential effective corporate governance||Vote 2Large, significant company, ESG related proposal||Vote 3Large, significant company, ESG related proposal|
Number of fund engagements undertaken by topic – DC Section
The table below sets out the number of engagements by topic undertaken by DC managers during the year. Engagements include multiple company meetings held by managers during the year with the same company. Most engagement conversations cover multiple topics and are based on investment manager vote guidelines and engagement priorities.
|Fund name||Manager 1UKRF Sustainable Equity Fund||Manager 2UKRF Diversified Growth Fund||Manager 2UKRF Global (ex-UK) Equity Index Fund||Manager 2UKRF Emerging Markets Equity Index Fund||Manager 2UKRF UK Equity Index Fund||Manager 2UKRF Sterling Corporate Bond Fund|
|E - Climate Risk Management||Jupiter4||Manager 2744||Manager 2742||Manager 2249||Manager 21,314||Manager 270|
|E - Environmental Impact Management||Jupiter5||Manager 2336||Manager 2314||Manager 2132||Manager 2575||Manager 226|
|E - Operational Sustainability||Jupiter-||Manager 2495||Manager 2423||Manager 2161||Manager 2792||Manager 239|
|S - Human Capital Management||Jupiter3||Manager 2479||Manager 2501||Manager 298||Manager 2792||Manager 236|
|S - Social Risks and Opportunities||Jupiter3||Manager 2303||Manager 2293||Manager 298||Manager 2487||Manager 234|
|G - Board Composition and Effectiveness||Jupiter9||Manager 2808||Manager 2708||Manager 2221||Manager 21,393||Manager 266|
|G - Business Oversight/Risk Management||Jupiter2||Manager 2411||Manager 2339||Manager 2192||Manager 2697||Manager 231|
|G - Corporate Strategy||Jupiter7||Manager 2616||Manager 2613||Manager 2220||Manager 21,114||Manager 258|
|G - Executive Management||Jupiter3||Manager 2218||Manager 2175||Manager 2112||Manager 2397||Manager 228|
|G - Governance Structure||Jupiter-||Manager 2382||Manager 2417||Manager 2157||Manager 2732||Manager 215|
|G - Remuneration||Jupiter1||Manager 2646||Manager 2553||Manager 2106||Manager 21,018||Manager 263|