nei corporate engagement focus list - … list 2017... · nei corporate engagement focus list q3...

NEI Corporate Engagement Focus ListQ3 Update: October 2017

Company Overview ESG Issues Dialogue Results Holdings

CONSUMER

Aritzia

Aritzia is a Canadianwomen's fashion appareland accessories retailcompany.

www.aritzia.com

• Responsibility to respecthuman rights - supply chain

• Governance matters -enhancing ESG disclosure

In September 2017 we followed up on our earlier discussionswith Aritzia on ESG disclosure, sharing additional resources ongood practice in corporate climate change disclosure, focusingon the recommendations of the FSB Task Force onClimate-related Disclosure.

NEI Ethical SpecialEquity Fund

Colgate-Palmolive

Colgate-Palmolive is anAmerican household, healthcare and personal careproducts company.

www.colgatepalmolive.com

• Energy transition -climate strategy, GHGemissions & public policy

In September 2017 we were part of the collaborative investorinitiative RE100 that wrote to Colgate-Palmolive asking thecompany to commit to setting a target for sourcing 100% of itselectricity from renewable sources.

NEI Ethical GlobalDividend Fund

NEI GenerationalLeaders Fund

NEI NorthwestGlobal Equity Fund

Ford

Ford Motor Company (Ford)is an Americanmultinational automobilemaker, founded in 1903.

www.ford.com


In September 2017 we were part of the collaborative investorinitiative RE100 that wrote to Ford asking the company tocommit to setting a target for sourcing 100% of its electricityfrom renewable sources.

NEI Ethical GlobalEquity Fund

http://www.aritzia.com

http://www.colgatepalmolive.com

http://www.ford.com


Heineken

Heineken International(Heineken) is a Dutchbrewing company foundedin 1864, producing beersand ciders in over 70countries.

www.theheinekencompany.com


In September 2017 we were part of the collaborative investorinitiative RE100 that wrote to Heineken asking the company tocommit to setting a target for sourcing 100% of its electricityfrom renewable sources.

NEI EthicalInternational Equity

Fund

Kellogg

The Kellogg Company is amultinational food companyheadquartered in Michigan.

www.kelloggcompany.com


In September 2017 we were part of the collaborative investorinitiative RE100 that wrote to Kellogg asking the company tocommit to setting a target for sourcing 100% of its electricityfrom renewable sources.


Kingfisher

Kingfisher is a Britishmultinational retailingcompany, with brandsincluding B&Q; andCastorama.

www.kingfisher.com


In September 2017 we were part of the collaborative investorinitiative RE100 that wrote to Kingfisher asking the company tocommit to setting a target for sourcing 100% of its electricityfrom renewable sources.


Fund

Lassonde

Lassonde Industries is aQuebec-based foodcompany.

www.lassonde.com



Responding to a request made in earlier dialogue, Lassondepublished its supplier code. We met with Lassonde inSeptember 2017 to discuss labour practices in the company'ssupply chain, its supply chain accountability structure, and howit could enhance ESG disclosure to investors. We commendedthe progress the company had made on supply chaindisclosure.


NEI NorthwestSpeciality Equity

Fund

http://www.theheinekencompany.com

http://www.kelloggcompany.com

http://www.kingfisher.com

http://www.lassonde.com


Leon's

Leon’s is a Canadianfurniture and applianceretailer.

www.leons.ca



In September 2017, we wrote to Leon's explaining our proxyvoting decisions at the company's 2017 Annual Meeting.Specifically, we encouraged the company to resolvegovernance concerns such as the level of board andcompensation committee independence and the lack of anominating committee of the board.


LKQCorporation

LKQ Corporation is anAmerican auto partscompany that provideswholesale used andrefurbished auto parts.

www.lqkcorp.com


In September 2017, in the context of our engagementcollaboration with partners in the Impax EnvironmentalLeaders strategy, we received a response to our letter to LKQasking the company to enhance its ESG disclosure. Thecompany acknowledged the importance of ESG issues,including energy efficiency, health and safety, and diversity.LKQ indicated that it would consider further disclosure.

NEI EnvironmentalLeaders Fund

LVMH

LVMH Moët Hennessy LouisVuitton (LVMH) is a Frenchmultinational luxury goodscompany.

www.LVHM.com


In September 2017 we were part of the collaborative investorinitiative RE100 that wrote to LVMH asking the company tocommit to setting a target for sourcing 100% of its electricityfrom renewable sources.


Fund



http://www.leons.ca

http://www.lqkcorp.com

http://www.LVHM.com


Metro

Metro Inc. is a food retaileroperating in the provincesof Quebec and Ontario,based in Montreal.

www.metro.ca


• Farm to fork - access tonutrition, food waste &animal welfare

Following up on our earlier meeting, we wrote to Metro inSeptember 2017 to provide feedback on the company'sResponsible Procurement Framework and Supplier Code ofConduct for Responsible Procurement. We asked how thecompany is enforcing supply chain responsibility standardsthrough the use of third party audits of suppliers. We alsohighlighted investor interest in sustainable sourcing of specificcommodities such as palm oil, meat and poultry raised withoutroutine use of antibiotics and cane sugar, as well as food wasteinitiatives such as the National Zero Waste Council.

NEI EthicalBalanced Fund

NEI EthicalCanadian Equity

Fund

NEI NorthwestSpecialty Equity

Fund

NEI NorthwestCanadian Dividend

Fund

Nestlé

Nestlé is a global nutritionand health company,headquartered inSwitzerland.

www.nestle.com

• Farm to fork - Animalwelfare

In September 2017 we joined an investor coalition that wrote toNestlé to highlight investor expectations related to combattingchild labour in the cocoa industry.


Fund

http://www.metro.ca

http://www.nestle.com


PepsiCo

PepsiCo is an Americanmultinational food, snackand beverage corporation.

www.pepsico.com

• Farm to fork - access tonutrition

• Governance matters -policy lobbying


In September 2017 we participated in an ICCR collaborativeinvestor dialogue with PepsiCo. We discussed companyinitiatives and strategy on access to nutrition, sustainableagriculture, responsible sourcing, and water and wastewatermanagement. We encouraged the company to continue tomake strides on sustainability issues.

Also in September 2017, we were part of the collaborativeinvestor initiative RE100 that wrote to PepsiCo asking thecompany to commit to setting a target for sourcing 100% of itselectricity from renewable sources.

NEI Ethical U.S.Equity Fund


NEI Northwest USDividend Fund

NEI NorthwestTactical Yield Fund

PSA PeugeotCitroën

Groupe PSA (PSA PeugeotCitroën) is a Frenchmultinational manufacturerof automobiles andmotorcycles.

www.groupe-psa.com


In September 2017 we were part of the collaborative investorinitiative RE100 that wrote to PSA asking the company tocommit to setting a target for sourcing 100% of its electricityfrom renewable sources.


http://www.pepsico.com

http://www.groupe-psa.com


RestaurantBrands

Restaurant BrandsInternational is theCanada-based holdingcompany for Tim Hortonsand Burger King.

www.rbi.com

• Farm to fork - animalwelfare

In the context of a PRI collaboration on labour and humanrights in the agricultural supply chain, we led a meeting withRestaurant Brands in September 2017 to discuss the company'sVendor Code. We commended Restaurant Brands for disclosingits Vendor Code, responding to a request in earlier dialogue.We discussed the company's process and accountabilitystructure in relation to the Vendor Code, as well as the farmanimal welfare goals disclosed in its 2016 Sustainability Report.We encouraged Restaurant Brands to report annually onprogress against the goals.

Also in September 2017, we wrote to Restaurant Brands toprovide feedback on how we voted at the company's 2017Annual Meeting. We encouraged the company to addresscorporate governance issues such as director over-boarding,board interlocks, lack of board diversity, and excessive NEOcompensation. In light of the company's dual class sharestructure, we gave our perspective on the importance ofincluding independent and diverse directors on the board.



Fund

SandersonFarms

Sanderson Farms is thethird largest poultryproducer in the U.S.

www.sandersonfarms.com

• Farm to fork - animalwelfare

In September 2017 we were part of a collaboration that wroteto Sanderson Farms highlighting investor interest in concernsrelating to routine antibiotic use in livestock. We outlined thepotential reputational, regulatory and litigation risks of routineantibiotic use and encouraged Sanderson to strengthenantibiotic stewardship policies.


http://www.rbi.com

http://www.sandersonfarms.com


ENERGY

Chevron

Chevron Energy is one ofthe world’s largestintegrated oil & gascompanies, headquarteredin California, U.S.

www.chevron.com


Chevron was one of several U.S.-based companies we met within Houston in July 2017 for an investor-company dialogue toshare views on the role of climate change scenario analysis foroil and gas companies.


NEI Northwest U.S.Dividend Fund


CNRL

Canadian NaturalResources Limited (CNRL)is an oil and gasexploration, developmentand production companywith its corporate headoffice in Calgary, Alberta.

www.cnrl.com


In August 2017, as part of the PRI methane collaboration, wewere one of a group of investors that met with the President ofCNRL to discuss the company's ongoing strategy for reducingmethane emissions. Topics included the company's stance onfederal and provincial regulations, improving disclosure onmethane, and future plans for reducing its methane emissionfootprint.


Fund



Fund

http://www.chevron.com

http://www.cnrl.com


Enbridge

Enbridge is an energyinfrastructure companybased in Alberta, Canada. Itfocuses on thetransportation, distributionand generation of energy,primarily in North America.

www.enbridge.com


• Aboriginal engagementstrategy

In July 2017 we met with Enbridge's Houston staff to discussmethane management regarding legacy Spectra assets in theU.S. Spectra Energy had developed a strong program onmethane emission reductions and continued to seek furtheropportunities to improve. Due to the merger, disclosure onlegacy Spectra assets had not been updated. Enbridgeindicated that it planned to incorporate the new assets intopublic disclosure in the coming year. We also discussed thecompany's progress in setting GHG reduction targets for newU.S. assets.


Fund (EnbridgeIncome Fund

Holdings)

ExxonMobil

Exxon, headquartered inHouston, Texas, is theworld’s largest publiclytraded oil & gas company.

www.exxonmobil.com


In September 2017 Exxon announced a corporate strategy toreduce its methane emission footprint. The company strategywould focus on fugitive emissions and emissions frompneumatic valves - both key methane sources for the company.Exxon also committed to significantly increase R&D; intosolutions for methane emissions, including finding ways toeliminate the emissions associated with pneumatics. Investorshad been asking the company to enhance its management ofmethane emissions, and we voted in favour of a shareholderresolution on this issue at the company's 2017 AGM. We sawthis commitment as a significant development that couldinfluence other companies to follow suit.




Mullen Group

Mullen Group providesspecialized transportationand related services to theoil and natural gas industryin western Canada.

www.mullen-group.com



In September 2017 we wrote to Mullen to explain our proxyvoting decisions at the company's 2017 Annual Meeting. Wecommended the company for actively seeking to enhance thediversity of its board through the addition of two womendirectors. Increasing the diversity of the board had been anongoing request to the company in our dialogue. We alsocommended Mullen for the significant emphasis on employeesafety in its executive compensation framework andencouraged the company to continue to improve its disclosureon key ESG issues.


http://www.enbridge.com

http://www.exxonmobil.com

http://www.mullen-group.com


OccidentalPetroleum

Occidental Petroleum is aninternational oil & gascompany with operations inthe United States, MiddleEast and Latin America.

www.oxy.com


In July 2017 we met with Occidental staff to discuss thecompany's plans to address the shareholder resolutionrequesting a report on its strategy for a low-carbon future,which had received majority support at the AGM. We sharedour views on best practice in this area and learned that thecompany was already working on the report structure.

Also in July 2017, Occidental was one of several U.S.-basedcompanies we met with in Houston for an investor-companydialogue to share views on the role of climate change scenarioanalysis for oil and gas companies.



Suncor

Suncor Energy Inc. isCanada’s largest integratedenergy company, focusedon development of theAthabasca oil sands.

www.suncor.com


In September 2017 we met with Suncor to provide feedback onits current corporate disclosures and to give guidance on itsstrategy for future disclosure. The company is keen to ensureits ESG disclosures are linked to its strategic imperatives andthat its external disclosure is driving internal performance.



Fund

http://www.oxy.com

http://www.suncor.com


FINANCIAL

ABN Amro

ABN Amro is a Dutch bankheadquartered inAmsterdam.

www.abnamro.com

• Responsibility to respecthuman rights

This dialogue was added during 2017 in response to emergingESG risks and opportunities. In August 2017 we wrote to ABNAmro, an Equator Principles member, to express appreciationfor its active support for the strengthening of the EquatorPrinciples framework for responsible lending. We highlightedthat assumptions about the adequacy of indigenous rightsprovisions in higher-income countries had contributed to riskfor the bank and other financial institutions in the projectfinance consortium for the controversial Dakota AccessPipeline, and expressed support for broad application of theInternational Finance Corporation Performance Standards inthese situations. The bank responded to our letter, noting thatthe Equator Principles Association would discuss this issue atits Annual Meeting in October 2017.



AXA

AXA is a Frenchmultinational financialservices and insurancecompany, headquartered inParis.

www.axa.com

• Energy transition -renewable energy targets

We were part of the investor collaboration RE100 that askedAXA to commit to setting targets for sourcing 100% of theirelectricity from renewable sources. In July 2017 the companyannounced that it would be joining the coalition effort andcommitting to the 100% sourcing goal.


BancoSantander

Banco Santander is aSpanish banking group.

www.bancosantander.es


This dialogue was added during 2017 in response to emergingESG risks and opportunities. In September 2017, we wrote toBanco Santander, an Equator Principles member, to supportstrengthening the Equator Principles framework forresponsible lending. We highlighted that assumptions about theadequacy of indigenous rights provisions in higher-incomecountries had contributed to risk for financial institutions in theproject finance consortium for the controversial Dakota AccessPipeline, and expressed support for broad application of theInternational Finance Corporation Performance Standards inthese situations.

NEI Global TotalReturn Bond Fund

http://www.abnamro.com

http://www.axa.com

http://www.bancosantander.es


Bank ofAmerica

Bank of AmericaCorporation is amultinational banking andfinancial servicescorporation, and one of thelargest banks in the UnitedStates.

www.bankofamerica.com


This dialogue was added during 2017 in response to emergingESG risks and opportunities. In August 2017, we wrote to Bankof America, an Equator Principles member, to supportstrengthening the Equator Principles framework forresponsible lending. We highlighted that assumptions about theadequacy of indigenous rights provisions in higher-incomecountries had contributed to risk for financial institutions in theproject finance consortium for the controversial Dakota AccessPipeline, and expressed support for broad application of theInternational Finance Corporation Performance Standards inthese situations. We also raised possible risks to the bankrelated to its decision to finance the expansion of the KinderMorgan Pipeline.




Fund

Bank ofMontreal

BMO Financial Group is afinancial services providerthat serves more than 12million personal,commercial, corporate andinstitutional customers inNorth America andinternationally.

www.bmo.com

• Energy transition -climate finance


• Governance matters

In September 2017, we wrote to BMO, an Equator Principlesmember, to support strengthening the Equator Principlesframework for responsible lending. We highlighted thatassumptions about the adequacy of indigenous rightsprovisions in higher-income countries had contributed to riskfor financial institutions in the project finance consortium forthe controversial Dakota Access Pipeline, and expressedsupport for broad application of the International FinanceCorporation Performance Standards in these situations. Wealso raised possible risks to the bank related to its decision tofinance the expansion of the Kinder Morgan Pipeline. The bankresponded to our letter, noting that the Equator PrinciplesAssociation would discuss this issue at its Annual Meeting inOctober 2017.


Fund

http://www.bankofamerica.com

http://www.bmo.com


Bankinter

Bankinter is a Spanish bankheadquartered in Madrid.

www.bankinter.com


This dialogue was added during 2017 in response to emergingESG risks and opportunities. In September 2017, we wrote toBankinter, an Equator Principles member, to supportstrengthening the Equator Principles framework forresponsible lending. We highlighted that assumptions about theadequacy of indigenous rights provisions in higher-incomecountries had contributed to risk for financial institutions in theproject finance consortium for the controversial Dakota AccessPipeline, and expressed support for broad application of theInternational Finance Corporation Performance Standards inthese situations.


Barclays

Barclays is a Britishmultinational bank andfinancial services companyheadquartered in London.

www.home.barclays.com


This dialogue was added during 2017 in response to emergingESG risks and opportunities. In August 2017, we wrote toBarclays, an Equator Principles member, to supportstrengthening the Equator Principles framework forresponsible lending. We highlighted that assumptions about theadequacy of indigenous rights provisions in higher-incomecountries had contributed to risk for financial institutions in theproject finance consortium for the controversial Dakota AccessPipeline, and expressed support for broad application of theInternational Finance Corporation Performance Standards inthese situations. We also raised possible risks to the bankrelated to its decision to finance the expansion of the KinderMorgan Pipeline.


NEI GlobalStrategic Yield

Fund

NEI ConservativeYield Portfolio

http://www.bankinter.com

http://www.home.barclays.com


BBVA

Banco Bilbao VizcayaArgentaria (BBVA) is amultinational Spanishbanking group.

www.bbva.com


This dialogue was added during 2017 in response to emergingESG risks and opportunities. In August 2017, we wrote to BBVA,an Equator Principles member, to express appreciation for itsactive support for the strengthening of the Equator Principlesframework for responsible lending. We highlighted thatassumptions about the adequacy of indigenous rightsprovisions in higher-income countries had contributed to riskfor the bank and other financial institutions in the projectfinance consortium for the controversial Dakota AccessPipeline, and expressed support for broad application of theInternational Finance Corporation Performance Standards inthese situations.


BNP Paribas

BNP Paribas is a Frenchmultinational bank andfinancial services companyheadquartered in Paris,France.

www.group.bnpparibas.com


This dialogue was added during 2017 in response to emergingESG risks and opportunities. In August 2017, we wrote to BNPParibas, an Equator Principles member, to express appreciationfor its active support for the strengthening of the EquatorPrinciples framework for responsible lending. We highlightedthat assumptions about the adequacy of indigenous rightsprovisions in higher-income countries had contributed to riskfor the bank and other financial institutions in the projectfinance consortium for the controversial Dakota AccessPipeline, and expressed support for broad application of theInternational Finance Corporation Performance Standards inthese situations.


CaixaBank

CaixaBank is a Spanishfinancial services companyheadquartered in Valencia,Spain.

www.caixabank.com


This dialogue was added during 2017 in response to emergingESG risks and opportunities. In September 2017 we wrote toCaixaBank, an Equator Principles member, to supportstrengthening the Equator Principles framework forresponsible lending. We highlighted that assumptions about theadequacy of indigenous rights provisions in higher-incomecountries had contributed to risk for financial institutions in theproject finance consortium for the controversial Dakota AccessPipeline, and expressed support for broad application of theInternational Finance Corporation Performance Standards inthese situations.


(SOLD)

http://www.bbva.com

http://www.group.bnpparibas.com

http://www.caixabank.com


CanadianWestern Bank

Canadian Western Bank andits operating affiliates offera diversified range offinancial services.

www.cwbankgroup.com


In August 2017 we wrote to the board of Canadian WesternBank to provide feedback on our proxy voting at the company's2017 AGM. We were able to support all managementrecommendations on the ballot, although we expressed somereservations about use of discretion and deviation from theperformance metrics framework in compensationdecision-making. We recognized that previous concernsrelating to over-boarding of directors had been resolved, andthat the company had met its initial board diversity targetearly. We also noted that its directors skills matrix, whichincorporates an assessment of skill levels, is a good practiceexample. Canadian Western Bank responded to our letter,expressing openness to further dialogue.


CIBC

CIBC is a leadingCanadian-based financialinstitution and provides afull suite of financialproducts and services inCanada and around theworld.

www.cibc.com




In September 2017 we wrote to CIBC, an Equator Principlesmember, to support strengthening the Equator Principlesframework for responsible lending. We highlighted thatassumptions about the adequacy of indigenous rightsprovisions in higher-income countries had contributed to riskfor financial institutions in the project finance consortium forthe controversial Dakota Access Pipeline, and expressedsupport for broad application of the International FinanceCorporation Performance Standards in these situations. Wealso raised possible risks to the bank related to its decision tofinance the expansion of the Kinder Morgan Pipeline. The bankresponded to our letter, noting that the Equator PrinciplesAssociation will discuss this issue at its Annual Meeting inOctober 2017.



Fund



Fund

http://www.cwbankgroup.com

http://www.cibc.com


Citigroup Inc.

Citigroup is an Americanmultinational investmentbanking and financialservices corporation.

www.citigroup.com

• Governance matters -business ethics


This dialogue was added during 2017 in response to emergingESG risks and opportunities. In August 2017, we wrote toCitigroup, an Equator Principles member, to expressappreciation for its active support for the strengthening of theEquator Principles framework for responsible lending. Wehighlighted that assumptions about the adequacy of indigenousrights provisions in higher-income countries had contributed torisk for the bank and other financial institutions in the projectfinance consortium for the controversial Dakota AccessPipeline, and expressed support for broad application of theInternational Finance Corporation Performance Standards inthese situations.

In September 2017, we joined an ICCR collaborativeengagement meeting with Citigroup to follow-up on earlierdialogue on ethical business conduct and to understand thecompany's perspectives on regulatory reforms affectingconsumer protection in the U.S.

NEI NorthwestCanadian Equity

Fund


Fund

Crédit Agricole

Crédit Agricole is a Frenchnetwork of cooperative andmutual banks,headquartered inMontrouge, France.

www.credit-agricole.com


This dialogue was added during 2017 in response to emergingESG risks and opportunities. In August 2017 we wrote to CréditAgricole, an Equator Principles member, to expressappreciation for its active support for the strengthening of theEquator Principles framework for responsible lending. Wehighlighted that assumptions about the adequacy of indigenousrights provisions in higher-income countries had contributed torisk for the bank and other financial institutions in the projectfinance consortium for the controversial Dakota AccessPipeline, and expressed support for broad application of theInternational Finance Corporation Performance Standards inthese situations.


http://www.citigroup.com

http://www.credit-agricole.com


Credit SuisseGroup

Credit Suisse Group is aSwiss multinationalfinancial services holdingcompany founded in 1856.

www.credit-suisse.com


This dialogue was added during 2017 in response to emergingESG risks and opportunities. In September 2017 we wrote toCredit Suisse, an Equator Principles member, to supportstrengthening the Equator Principles framework forresponsible lending. We highlighted that assumptions about theadequacy of indigenous rights provisions in higher-incomecountries had contributed to risk for financial institutions in theproject finance consortium for the controversial Dakota AccessPipeline, and expressed support for broad application of theInternational Finance Corporation Performance Standards inthese situations. The bank responded to our letter, noting thatthe Equator Principles Association will discuss this issue at itsAnnual Meeting in October 2017.


DNB

DNB (Den Norske Bank) isNorway's largest financialservices group,headquartered in Oslo.

www.dnb.no


This dialogue was added during 2017 in response to emergingESG risks and opportunities. In September 2017 we wrote toDNB, an Equator Principles member, to support strengtheningthe Equator Principles framework for responsible lending. Wehighlighted that assumptions about the adequacy of indigenousrights provisions in higher-income countries had contributed torisk for the bank and other financial institutions in the projectfinance consortium for the controversial Dakota AccessPipeline, and expressed support for broad application of theInternational Finance Corporation Performance Standards inthese situations.


FirstRand

FirstRand is a financialservices provider in SouthAfrica, headquartered inJohannesburg.

www.firstrand.co


This dialogue was added during 2017 in response to emergingESG risks and opportunities. In September 2017 we wrote toFirstRand, an Equator Principles member, to supportstrengthening the Equator Principles framework forresponsible lending. We highlighted that assumptions about theadequacy of indigenous rights provisions in higher-incomecountries had contributed to risk for financial institutions in theproject finance consortium for the controversial Dakota AccessPipeline, and expressed support for broad application of theInternational Finance Corporation Performance Standards inthese situations.

NEI NorthwestEmerging Markets

Fund

http://www.credit-suisse.com

http://www.dnb.no

http://www.firstrand.co


ING Group

ING Group is a multinationalbanking and financialservices corporation,headquartered in theNetherlands.

www.ing.com


• Responsibility to respecthuman rights - FPIC

In September 2017 we wrote to ING, an Equator Principlesmember, to support strengthening the Equator Principlesframework for responsible lending. We highlighted thatassumptions about the adequacy of indigenous rightsprovisions in higher-income countries had contributed to riskfor the bank and other financial institutions in the projectfinance consortium for the controversial Dakota AccessPipeline, and expressed support for broad application of theInternational Finance Corporation Performance Standards inthese situations.


Fund



Fund

Intesa Sanpaolo

Intesa Sanpaolo is an Italianbanking and financialservices group.

www.intesasanpaolo.com


This dialogue was added during 2017 in response to emergingESG risks and opportunities. In August 2017 we wrote to IntesaSanpaolo, an Equator Principles member, to expressappreciation for its active support for the strengthening of theEquator Principles framework for responsible lending. Wehighlighted that assumptions about the adequacy of indigenousrights provisions in higher-income countries had contributed torisk for the bank and other financial institutions in the projectfinance consortium for the controversial Dakota AccessPipeline, and expressed support for broad application of theInternational Finance Corporation Performance Standards inthese situations.


http://www.ing.com

http://www.intesasanpaolo.com


Itaú Unibanco

Itaú Unibanco is the largestLatin American bank, basedin São Paulo, Brazil.

www.itauunibancoir.com


This dialogue was added during 2017 in response to emergingESG risks and opportunities. In September 2017, we wrote toItaú Unibanco, an Equator Principles member, to supportstrengthening the Equator Principles framework forresponsible lending. We highlighted that assumptions about theadequacy of indigenous rights provisions in higher-incomecountries had contributed to risk for financial institutions in theproject finance consortium for the controversial Dakota AccessPipeline, and expressed support for broad application of theInternational Finance Corporation Performance Standards inthese situations.

NEI NorthwestEmerging Markets

Fund

JPMorganChase

JPMorgan Chase & Co. is aleading global financialservices firm and one of thelargest banking institutionsin the United States, withoperations worldwide.

www.jpmorganchase.com



This dialogue was added during 2017 in response to emergingESG risks and opportunities. In September 2017 we wrote toJPMorgan Chase, an Equator Principles member, to supportstrengthening the Equator Principles framework forresponsible lending. We highlighted that assumptions about theadequacy of indigenous rights provisions in higher-incomecountries had contributed to risk for financial institutions in theproject finance consortium for the controversial Dakota AccessPipeline, and expressed support for broad application of theInternational Finance Corporation Performance Standards inthese situations. We also raised possible risks to the bankrelated to its decision to finance the expansion of the KinderMorgan Pipeline. The bank responded to our letter, andexplained what risk management system and frameworks it hasin place to implement the Equator Principles.



Fund



Fund

http://www.itauunibancoir.com

http://www.jpmorganchase.com


KBC Group

KBC Group is a Belgianretail and financial servicesbank, headquartered inBrussels.

www.kbc.com


This dialogue was added during 2017 in response to emergingESG risks and opportunities. In September 2017 we wrote toKBC Group, an Equator Principles member, to supportstrengthening the Equator Principles framework forresponsible lending. We highlighted that assumptions about theadequacy of indigenous rights provisions in higher-incomecountries had contributed to risk for financial institutions in theproject finance consortium for the controversial Dakota AccessPipeline, and expressed support for broad application of theInternational Finance Corporation Performance Standards inthese situations. The bank responded to our letter, sharing thehuman rights commitments it has in place.


LaurentianBank

Laurentian Bank of Canadais a Quebec bankinginstitution operating acrossCanada, providing a fullsuite of financial products.

www.laurentianbank.com


In August 2017 we wrote to the board of Laurentian to providefeedback on our voting at the 2017 AGM. We explained ourdecision to support the compensation plan despite somereservations about disclosure of the frameworkof metrics anda relatively high proportion of time-based incentives, inrecognition of efforts made to address earlier concerns aboutexcessive quantum of pay. We shared our views on the value of"gender-neutral" board diversity targets with the bank, whichhas been a diversity leader.


NEI NorthwestSpecial Equity Fund


Fund

Lloyds BankingGroup

Lloyds Banking Group is aleading British financialinstitution, founded in 1695by the Bank of Scotland.

www.lloydsbankinggroup.com


This dialogue was added during 2017 in response to emergingESG risks and opportunities. In September 2017 we wrote toLloyds Banking Group, an Equator Principles member, tosupport strengthening the Equator Principles framework forresponsible lending. We highlighted that assumptions about theadequacy of indigenous rights provisions in higher-incomecountries had contributed to risk for financial institutions in theproject finance consortium for the controversial Dakota AccessPipeline, and expressed support for broad application of theInternational Finance Corporation Performance Standards inthese situations.


http://www.kbc.com

http://www.laurentianbank.com

http://www.lloydsbankinggroup.com


Manulife

Manulife Financial is aCanadian-based financialservices group

www.manulife.ca


This dialogue was added during 2017 in response to emergingESG risks and opportunities. In September 2017 we wrote toManulife, an Equator Principles member, to supportstrengthening the Equator Principles framework forresponsible lending. We highlighted that assumptions about theadequacy of indigenous rights provisions in higher-incomecountries had contributed to risk for financial institutions in theproject finance consortium for the controversial Dakota AccessPipeline, and expressed support for broad application of theInternational Finance Corporation Performance Standards inthese situations.


NEI NorthwestGrowth & Income

Fund


Fund


Fund

Mizuho Bank

Mizuho Bank is a leadingfinancial services companyin Japan, headquartered inTokyo.

www.mizuhobank.com


This dialogue was added during 2017 in response to emergingESG risks and opportunities. In September 2017 we wrote toMizuho Bank, an Equator Principles member, to supportstrengthening the Equator Principles framework forresponsible lending. We highlighted that assumptions about theadequacy of indigenous rights provisions in higher-incomecountries had contributed to risk for the bank and otherfinancial institutions in the project finance consortium for thecontroversial Dakota Access Pipeline, and expressed supportfor broad application of the International Finance CorporationPerformance Standards in these situations. We also raisedpossible risks to the bank related to its decision to finance theexpansion of the Kinder Morgan Pipeline.


http://www.manulife.ca

http://www.mizuhobank.com


Natixis

Natixis is a French financialservices company based inParis, France.

www.natixis.com


This dialogue was added during 2017 in response to emergingESG risks and opportunities. In August 2017 we wrote toNatixis, an Equator Principles member, to express appreciationfor its active support for the strengthening of the EquatorPrinciples framework for responsible lending. We highlightedthat assumptions about the adequacy of indigenous rightsprovisions in higher-income countries had contributed to riskfor the bank and other financial institutions in the projectfinance consortium for the controversial Dakota AccessPipeline, and expressed support for broad application of theInternational Finance Corporation Performance Standards inthese situations.


Nordea Bank

Nordea Bank is a Nordicfinancial services groupwith offices worldwide,primarily providing servicesin Nordic and Balticcountries.

www.nordea.com


This dialogue was added during 2017 in response to emergingESG risks and opportunities. In September 2017 we wrote toNordea Bank, an Equator Principles member, to supportstrengthening the Equator Principles framework forresponsible lending. We highlighted that assumptions about theadequacy of indigenous rights provisions in higher-incomecountries had contributed to risk for financial institutions in theproject finance consortium for the controversial Dakota AccessPipeline, and expressed support for broad application of theInternational Finance Corporation Performance Standards inthese situations.


Rabobank

Coöperatieve Rabobank(Rabobank) is a Dutchmultinational banking andfinancial services company,primarily focused on foodand agriculture financing.

www.rabobank.com


This dialogue was added during 2017 in response to emergingESG risks and opportunities. In September 2017 we wrote toRabobank, an Equator Principles member, to supportstrengthening the Equator Principles framework forresponsible lending. We highlighted that assumptions about theadequacy of indigenous rights provisions in higher-incomecountries had contributed to risk for financial institutions in theproject finance consortium for the controversial Dakota AccessPipeline, and expressed support for broad application of theInternational Finance Corporation Performance Standards inthese situations.


http://www.natixis.com

http://www.nordea.com

http://www.rabobank.com


Royal Bank ofCanada

Royal Bank is Canada'slargest company by marketcapitalization, providingpersonal and commercialbanking, wealthmanagement services,insurance, investor servicesand capital marketsproducts and services on aglobal basis.

www.rbc.com




In August 2017 we wrote to RBC, an Equator Principlesmember, to support strengthening the Equator Principlesframework for responsible lending. We highlighted thatassumptions about the adequacy of indigenous rightsprovisions in higher-income countries had contributed to riskfor financial institutions in the project finance consortium forthe controversial Dakota Access Pipeline, and expressedsupport for broad application of the International FinanceCorporation Performance Standards in these situations. Wealso raised possible risks to the bank related to its decision tofinance the expansion of the Kinder Morgan Pipeline. The bankresponded to our letter, noting that the Equator PrinciplesAssociation will discuss this issue at its Annual Meeting inOctober 2017.


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Scotiabank

Scotiabank is a leadingfinancial services providerin over 55 countries and isCanada's most internationalbank.

www.scotiabank.com




In August 2017 we wrote to Scotiabank, an Equator Principlesmember, to support strengthening the Equator Principlesframework for responsible lending. We highlighted thatassumptions about the adequacy of indigenous rightsprovisions in higher-income countries had contributed to riskfor financial institutions in the project finance consortium forthe controversial Dakota Access Pipeline, and expressedsupport for broad application of the International FinanceCorporation Performance Standards in these situations. Wealso raised possible risks to the bank related to its decision tofinance the expansion of the Kinder Morgan Pipeline. The bankresponded to our letter, noting that the Equator PrinciplesAssociation will discuss this issue at its Annual Meeting inOctober 2017.



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http://www.rbc.com

http://www.scotiabank.com


SEB

Skandinaviska EnskildaBanken (SEB) is a Swedishfinancial services groupheadquartered inStockholm.

www.sebgroup.com


This dialogue was added during 2017 in response to emergingESG risks and opportunities. In September 2017 we wrote toSEB, an Equator Principles member, to support strengtheningthe Equator Principles framework for responsible lending. Wehighlighted that assumptions about the adequacy of indigenousrights provisions in higher-income countries had contributed torisk for financial institutions in the project finance consortiumfor the controversial Dakota Access Pipeline, and expressedsupport for broad application of the International FinanceCorporation Performance Standards in these situations.


SociétéGénérale

Société Générale is aFrench multinationalbanking and financialservices company,headquartered in Paris.

www.societegenerale.com


This dialogue was added during 2017 in response to emergingESG risks and opportunities. In August 2017, we wrote toSociété Générale, an Equator Principles member, to expressappreciation for its active support for the strengthening of theEquator Principles framework for responsible lending. Wehighlighted that assumptions about the adequacy of indigenousrights provisions in higher-income countries had contributed torisk for the bank and other financial institutions in the projectfinance consortium for the controversial Dakota AccessPipeline, and expressed support for broad application of theInternational Finance Corporation Performance Standards inthese situations. The bank responded to our letter, noting thatthe Equator Principles Association will discuss this issue.


http://www.sebgroup.com

http://www.societegenerale.com


SumitomoMitsui

Sumitomo Mitsui BankingCorporation is a Japanesemultinational banking andfinancial services company.

www.smbc.co.jp


This dialogue was added during 2017 in response to emergingESG risks and opportunities. In September 2017 we wrote toSumitomo Mitsui, an Equator Principles member, to supportstrengthening the Equator Principles framework forresponsible lending. We highlighted that assumptions about theadequacy of indigenous rights provisions in higher-incomecountries had contributed to risk for the bank and otherfinancial institutions in the project finance consortium for thecontroversial Dakota Access Pipeline, and expressed supportfor broad application of the International Finance CorporationPerformance Standards in these situations. We also raisedpossible risks to the bank related to its decision to finance theexpansion of the Kinder Morgan Pipeline.


http://www.smbc.co.jp


TD Bank

TD Bank Group,headquartered in Torontowith offices around theworld, offers a full range offinancial products andservices.

www.td.com




In August 2017, we wrote to TD, an Equator Principles member,to support strengthening the Equator Principles framework forresponsible lending. We highlighted that assumptions about theadequacy of indigenous rights provisions in higher-incomecountries had contributed to risk for the bank and otherfinancial institutions in the project finance consortium for thecontroversial Dakota Access Pipeline, and expressed supportfor broad application of the International Finance CorporationPerformance Standards in these situations. We also raisedpossible risks to the bank related to its decision to finance theexpansion of the Kinder Morgan Pipeline. The bank respondedto our letter, noting that the Equator Principles Association willdiscuss this issue at its Annual Meeting in October 2017.



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http://www.td.com


UniCredit

UniCredit SpA is an Italianbanking and financialservices company, offeringservices worldwide andheadquartered in Milan,Italy.

www.unitcreditgroup.eu


This dialogue was added during 2017 in response to emergingESG risks and opportunities. In September 2017 we wrote toUniCredit, an Equator Principles member, to supportstrengthening the Equator Principles framework forresponsible lending. We highlighted that assumptions about theadequacy of indigenous rights provisions in higher-incomecountries had contributed to risk for financial institutions in theproject finance consortium for the controversial Dakota AccessPipeline, and expressed support for broad application of theInternational Finance Corporation Performance Standards inthese situations.


http://www.unitcreditgroup.eu


Wells Fargo

Wells Fargo is an Americanmultinational financialservices company.

www.wellsfargo.com



In August 2017 we wrote to Wells Fargo, an Equator Principlesmember, to support strengthening the Equator Principlesframework for responsible lending. We highlighted thatassumptions about the adequacy of indigenous rightsprovisions in higher-income countries had contributed to riskfor financial institutions in the project finance consortium forthe controversial Dakota Access Pipeline, and expressedsupport for broad application of the International FinanceCorporation Performance Standards in these situations.

Also in August 2017, we wrote to the board of Wells Fargo toprovide feedback on our voting at the 2017 AGM and follow upon our co-filed shareholder proposal calling for acomprehensive business standards review in light of theunauthorized accounts scandal. We explained that we withheldour votes from all incumbent director nominees due to thematerial failures of ESG risk oversight at the company. Wewere able to support the executive compensation plan giventhe board's decision not to award bonuses and to claw backcompensation following the scandal. However, we found thecompany's contradictory statements on cross-selling troubling:cross-selling had been used to justify executive compensationbonuses for a number of years, yet according to the reportreleased by the bank in April 2017, the board was alreadyconcerned about cross-selling practices during the sameperiod. While we appreciated the corrective actions taken byWells Fargo so far, further scandals had emerged since theAGM, and we continued to urge the need for a holistic businessstandards review in order to prevent similar problems in future.Wells Fargo responded to our letter, explaining its boardrefreshment initiatives and offering further dialogue. Weindicated that we would continue to participate in the ICCRcollaborative dialogue.



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http://www.wellsfargo.com


Westpac

Westpac BankingCorporation (Westpac) is aleading Australian bank andfinancial services company,headquartered in Sydney.

www.westpac.com.au


This dialogue was added during 2017 in response to emergingESG risks and opportunities. In September 2017, we wrote toWestpac, an Equator Principles member, to supportstrengthening the Equator Principles framework forresponsible lending. We highlighted that assumptions about theadequacy of indigenous rights provisions in higher-incomecountries had contributed to risk for financial institutions in theproject finance consortium for the controversial Dakota AccessPipeline, and expressed support for broad application of theInternational Finance Corporation Performance Standards inthese situations. The bank responded to our letter, noting thatthe Equator Principles Association will discuss this issue at itsAnnual Meeting, and explained how ESG risks are assessed atall stages of its credit process.

NEI GIobal TotalReturn Bond Fund

HEALTH CARE

AgilentTechnologies

Agilent Technologies is anAmerican Healthcareequipment and servicescompany.

www.agilent.com

• Governance matters -board structure

In September 2017, as part of our engagement collaborationwith partners in the Impax Environmental Leaders strategy, wewrote to Agilent Technologies to follow-up on earlier dialogueon the company's board declassification and structure.


http://www.westpac.com.au

http://www.agilent.com


Cardinal Health

Cardinal Health is a leadingpharmaceutical and medicalproduct distributor,headquartered in Ohio, U.S.

www.cardinalhealth.com

• Better Pharma - opioidcrisis

In August 2017 we joined Investors for Opioid Accountability(IOA), a coalition of institutional investors addressing the NorthAmerican opioid crisis through engagement with opioidmanufacturers, opioid overdose treatment manufacturers andopioid distributors in our holdings. In September 2017 thecoalition wrote to Cardinal Health, an opioid distributor, toexpress our view that risks related to the company's role in theopioid crisis required board?level action. We asked how thecompany was building a culture in which ethical behavior andlegal compliance were valued, and urged adoption ofgovernance reforms such as an independent chair and thecreation of a special committee of independent directors toinvestigate and report to shareholders about Cardinal’s role inthe opioid epidemic.



DanaherCorporation

Danaher Corporation is anAmerican companydesigning, manufacturingand marketing industrialand consumer health andlife-sciences products.

www.danaher.com

• Governance matters -board capacity, diversity &ESG disclosure


As part of our engagement collaboration with partners in theImpax Environmental Leaders strategy, we wrote to DanaherCorporation in August 2017 to commend the company forenhancing corporate governance by amending its by-laws toprovide shareholders with a right to proxy access, and formeeting expectations in regard to board independence anddiversity. We also encouraged the company to considerenhancing overall disclosure to provide more insight into itsESG performance, in particular regarding GHG emissionsmanagement and overall climate change strategy.


Pfizer

Pfizer is a globalpharmaceutical companyheadquartered in the U.S.

www.pfizer.com

• Better pharma - drugpricing, access to medicine& SDGs


In September 2017, we participated in an ICCR dialogue withPfizer to discuss drug pricing, the pharmaceutical industry'sobligations to society, the company's role in the opioid crisis inNorth America, access to medicine and the company'sperspective on the new Access to Vaccines Index. The companynoted it is looking into increasing disclosure around drugpricing and discussed how it has been increasing sustainabilitydisclosure in line with the global Sustainable DevelopmentGoals. Pfizer expressed openness to dialogue on the opioidcrisis.



http://www.cardinalhealth.com

http://www.danaher.com

http://www.pfizer.com


Roche

Roche is a global healthcarecompany, headquartered inSwitzerland.

www.roche.com


In September 2017 we were part of the collaborative investorinitiative RE100 that wrote to Roche asking the company tocommit to setting a target for sourcing 100% of its electricityfrom renewable sources.




INDUSTRIALS

3M

3M is an Americanmultinationalconglomerate.

www.3m.com


In September 2017 we were part of the collaborative investorinitiative RE100 that wrote to 3M asking the company tocommit to setting a target for sourcing 100% of its electricityfrom renewable sources.


Acuity Brands

Acuity Brands is anAmerican electronicsmanufacturing companyspecializing in lightingequipment.

www.acuitybrands.com

• Governance matters -board capacity, equitablecompensation & enhancingESG disclosure

In August 2017 Acuity responded to our earlier letter givingfeedback on our proxy voting decisions, explaining its approachto corporate governance and agreeing to consider some of thepoints we had raised at its next board meeting. As well, thecompany expressed interest in a meeting to understand ourperspective on how it could improve its ESG disclosure.


Hubbell

Hubbell is an Americanmanufacturer of electricaland electronic products andlighting.

www.hubbell.com


In August 2017, as part of our engagement collaboration withpartners in the Impax Environmental Leaders strategy, we metwith Hubbell to discuss the company's plans for enhancing itsESG disclosure. The company had identified this as a gap andappreciated receiving investor input. It had recentlyimplemented corporate initiatives such as a company-wideenergy efficiency program and a program to enhancecorporate diversity.


http://www.roche.com

http://www.3m.com

http://www.acuitybrands.com

http://www.hubbell.com


Siemens

Siemens is a Germanconglomerate focused onindustry, energy,healthcare andinfrastructure,headquartered in Berlin.

www.siemens.com


In September 2017 we were part of the collaborative investorinitiative RE100 that wrote to Siemens asking the company tocommit to setting a target for sourcing 100% of its electricityfrom renewable sources.


INFORMATION TECHNOLOGY

CGI Group

CGI Group Inc. is amultinational informationtechnology consulting,systems integration,outsourcing, and solutionscompany headquartered inMontreal, Canada.

www.cgi.com

• Governance Matters -anti-corruption

• Enhancing ESGdisclosure

Following up on a request made in earlier dialogue, we wrote toCGI in September 2017 to commend the company forenhancing its disclosure on anti-corruption policies andenforcement. We were particularly pleased to see disclosure ofthe red flags the company uses to identify corruption-relatedrisks.



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http://www.siemens.com

http://www.cgi.com


IBM

International BusinessMachines Corp. (IBM) is amultinational hardware &information technologyservices company.

www.ibm.com

• Governance matters -executive compensation

We wrote to IBM in September 2017 to explain how we voted atthe company's most recent Annual Meeting and to relayconcerns about its executive compensation practices. In thecontext of our concerns about the impact of income inequalityon the economy, in 2017 we extended to the U.S. market ourproxy voting guideline capping the level of CEO pay that we cansupport based on a vertical comparison with median householdincome. North America has the highest CEO pay in the worldand U.S. income inequality is significant. IBM's CEO wasawarded over U.S.$50 million in total compensation in 2016, anextremely excessive amount compared to the medianhousehold income in the U.S., compensation at peer companies,and the pay of other IBM executives. We encouraged thecompany to respond to investor concerns about its executivecompensation framework.


NEI Global ValueFund

WatersCorporation

Waters Corporationservices the life sciencesindustry by manufacturinglaboratory equipment andsoftware.

www.waters.com

• Governance matters -board capacity, equitablecompensation & enhancingESG disclosure

In August 2017, as part of our engagement collaboration withpartners in the Impax Environmental Leaders strategy, wewrote to the board of Waters Corporation to commend thecompany for enhancing its corporate governance by amendingits by-laws to provide shareholders with a right to proxy accessand an annual advisory vote on executive compensation. Wealso encouraged the board to consider best practices in regardto director independence, tenure limits, over-boarding, andintegration of ESG performance into its annual incentive plan.


http://www.ibm.com

http://www.waters.com


MATERIALS

Agrium/Potash

Agrium is a globalagricultural products andservices companyproducing and marketingthree critical crop nutrients:potash, nitrogen andphosphate.

www.agrium.com


This dialogue was paused pending the outcome of theAgrium-Potash merger. The new entity, Nutrien, was expectedto be established by the end of 2017.



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Givaudan

Givaudan is a Swissmanufacturer of flavours,fragrances and cosmeticingredients.

www.givaudan.com


In September 2017 we were part of the collaborative investorinitiative RE100 that wrote to Givaudan asking the company tocommit to setting a target for sourcing 100% of its electricityfrom renewable sources.


http://www.agrium.com

http://www.givaudan.com


TELECOMMUNICATIONS

BCE

BCE is Canada’s largestcommunications company,offeringtelecommunications, mediaand other services underthe Bell brands.

www.bce.ca

• Governance matters -executive compensation,board diversity

In September 2017, we wrote to BCE to provide feedback onour proxy voting at the company's 2017 Annual Meeting. Wecommended the company for its continued commitment toboard diversity, and particularly for setting a goal to enhancediversity in executive positions. We encouraged the companyto consider framing gender diversity objectives in terms of aminimum percentage of both women and men. We expressedconcern about the limited proportion of performance-basedmetrics in the long-term compensation plan, noting that BCEfell short of best practice in Canada in this regard. Weencouraged enhanced disclosure of equitable pay practices andnoted that as a governance leader in Canada, BCE could playan important role in the development of equitablecompensation practice and disclosure.


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http://www.bce.ca


Collaborative Engagement

Food From Farm to Fork

• In September 2017 we participated in collaborative engagement led by As You Sow regarding the routine use of antibiotics in livestock at Sanderson Farms.

• We were signatory to an investor statement led by GES International on expectations for combatting child labour in the cocoa industry.

Getting Real about the Energy Transition

• In July 2017 we joined investors and companies in Houston, Texas to engage in a dialogue on effective corporate reporting on climate change risks and opportunities.Specifically, the event focused on the role of scenario analysis in helping companies assess their resilience to a low carbon future. Companies at the event included Occidental,Chevron, Enbridge, and Marathon.

• In July 2017 the RE100 investor collaboration reached the milestone of 100 companies agreeing to set targets to source 100% of the energy from renewable sources.

Governance Matters

• We continued to participate in ICCR's financial services collaboration, joining a meeting with Citigroup on ethical business conduct, and participating in discussions on follow-upwith Wells Fargo on the cross-selling scandal and other emerging customer protection issues.

Making Pharma Better

• We joined Investors for Opioid Accountability, a coalition of institutional investors addressing the North American opioid crisis through engagement with opioid manufacturers,opioid overdose treatment manufacturers and opioid distributors in our holdings.


Public Policy

Enabling Responsible Investment

• In July 2017 we signed ICCR's letter to the U.S. Senate, opposing the rollback of shareholder rights through provisions included in the CHOICE Act. In August 2017 we wrote tothe Alberta Government asking for changes in the regulations associated with the Businesss Corporations Act that would facilitate filing shareholder proposals. In September2017 we participated in PRI's consultation on enhancing accountability and leadership criteria for signatories.

Energy transition

• In August 2017 we submitted comments to the Government of Canada on its proposed framework for improving the environmental assessment process, affirming our supportfor the integration of strategic assessments of national environmental frameworks (such as climate change) and the use of regional strategic environmental assessments toaddress cumulative impacts, and commending the focus on reconciliation and early engagement with communities potentially impacted by projects.

• In July 2017 we submitted comments to the Government of Canada on its proposed regulations for reducing methane emissions from the oil and gas sector. We urged thegovernment to consider options for incenting companies to exceed the regulations, to ensure that company-level disclosure is accessible to stakeholders, to be transparentabout progress against national targets, and to ensure that the proposed regulations accurately capture all significant emission sources.

• In July 2017 we wrote to the Ontario and British Columbia Securities Commissions in response to the Canadian Securities Administrators' (CSA) Climate Change DisclosureReview Project. We noted that the current state of corporate reporting on climate-related risks was inadequate and urged the CSA to consider aligning disclosure expectationswith the Financial Stability Board's Task Force on Climate-Related Financial Disclosure. We also noted the importance of identifying climate change as a systemic risk and urgedthe CSA to consider requiring all companies to provide disclosure on the outcomes of a materiality assessment of ESG risks.

• In September 2017 we signed on to the Declaration of Institutional Investors on Climate-Related Financial Risks organized by Finance Montreal. The statement affirmedinvestor expectations that companies provide robust climate-related disclosure in line with the Financial Stability Board's Task Force on Climate-Related Financial Disclosurerecommendations.

• In August 2017 we were signatory to an investor letter to the U.S. Environmental Protection Agency urging it to stop delaying the implementation of methane emissionsstandards for the oil and gas industry, and affirming our support for robust regulations aimed at reducing methane emissions.

Food from Farm to Fork

• In August 2017 we submitted an investor perspective on plans for a Canadian Food Policy, highlighting issues including protection of pollinators, water, farm animal welfare,sustainable aquaculture, supply chain human rights, access to nutrition and food waste.

Governance Matters

• In September 2017 we participated in a further stage of consultation on the review of the Federal financial sector framework. Our submission called for transparency ininvestigation of consumer protection issues, governance enhancements in legislation governing financial institutions, increased focus on climate risk and sustainabledevelopment issues, and the convening of a High Level Expert Group on sustainable finance.


Responsibility to Respect

• In August 2017 we wrote to the Equator Principles Association to commend the creation of a working group tasked with assessing the application of the IFC PerformanceStandards for all Equator Principle projects - not only those in developing economies. Specifically, we noted that the IFC Performance Standards incorporated a requirement forfree, prior and informed consent that was more stringent than the provisions in many developed economies, and that adopting those standards could help to mitigate risks forinvestors.

• In August 2017 we met with Government of Canada representatives to discuss the implications of the Sustainable Development Goals (SDGs) for investors, and providefeedback on how the Government of Canada could align itself with the SDGs.

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