Shareholder Engagement Policy
(the "Policy")

Fisher Investments Luxembourg, Sàrl

September 2025

1. Introduction

1.1 Article 3g of the Shareholder Rights Directive II (EU/2017/828) (“SRD II”) requires institutional investors and asset managers to develop and publicly disclose an engagement policy that describes how they integrate shareholder engagement into their investment strategy.

1.2 Fisher Investments Luxembourg, Sàrl (“FIL”) delegates its portfolio management services, as well as other services covered by this Policy, to its parent company, Fisher Asset Management, LLC, trading as Fisher Investments (“FI”), subject to FIL’s oversight.

1.3 In compliance with the requirements of SRD II (as transposed in Luxembourg), FIL has put in place and made publicly accessible this Policy describing how FIL, and FI on behalf of FIL, integrates shareholder engagement into FIL’s investment strategy.

1.4 This Policy describes how FIL and FI, on behalf of FIL:

1. monitor FIL’s clients’ investee companies (the “companies”) on relevant matters (including strategy, financial and non-financial performance and risk, capital structure, social and environmental impact and corporate governance);
2. conduct dialogue with the companies;
3. exercise voting rights and other rights attached to shares of the companies;
4. co-operate with other shareholders;
5. communicate with relevant stakeholders; and
6. manage actual and potential conflicts of interests in relation to such engagements.

2. Scope

Consistent with the scope of SRD II, this Policy relates to FI’s management of FIL’s client accounts on behalf of FIL, which invest in shares traded on a regulated market in the European Economic Area.

3. How FIL and FI engage on behalf of FIL’s clients

FI is an active investment manager on behalf of its and its affiliates’ clients that engages with companies as part of its fundamental analysis and to clarify or express concerns over potential issues at the firm or industry level.

3.1 Monitoring of companies

FI has dedicated staff who work to identify risks and opportunities of FIL’s clients’ holdings on an ongoing basis. FI utilizes a combination of qualitative and quantitative information such as: MSCI Barra Analytics; Bloomberg; Factset; MSCI ESG Manager; company financial and sustainability disclosures, research from responsible investment network partners and relevant NGO reports. This information, supplemented by bottom up company research, is used to identify companies where there may be an opportunity for engagement. Engagements may also be considered when FI’s third party environmental, social and governance (“ESG”) ratings provider significantly downgrades a company’s rating; whenever concerns arise related to a company’s business, such as an announced restructuring plan, a pending corporate action, or a company’s activity results in it being assigned a red flag (severe controversy) by a third party data provider; or FI seeks to learn more about an upcoming proxy vote.

3.2 Dialogue with companies

FI’s experience shows stewardship concerns are usually best resolved by direct contact with company officials—whether at the board or management level. Escalating an issue beyond that point depends on the materiality of the issue, the company’s responses to past communications and whether FI believes such engagement is in the applicable FIL’s clients’ best interests. Corporate engagements may consist of letters, emails, conference calls, or in-person meetings with company representatives.

FI holds meetings with company management as necessary to discuss issues FI feels are pertinent to analysing the company or better understanding peers or relevant industry factors. Such discussions may include ESG issues that FI considers may have a material impact on the risk or return of an investment (“Sustainability Risks”). In addition, for FIL clients that have hired FIL to implement one or more ESG investment strategies or otherwise instructed FIL to consider non-Sustainability Risks ESG issues, FI may also clarify or express concerns over other ESG issues that are not Sustainability Risks with a company on behalf of those clients.

Information uncovered during engagement is incorporated into FI’s fundamental analysis. Depending on the issue, FI may engage in additional meetings with company management, intervene in concert with other institutions on the issue or meet with appropriate members of a company’s board. FI commonly engages with company management on proxy voting issues, particularly when Institutional Shareholder Services, Inc. (“ISS”) is in disagreement with company management. To encourage a real-time, active engagement dialogue, FI prefers either a phone call or in-person meeting with the company.

When appropriate, FI monitors the company’s progress and records milestones along the way.

3.3 Voting rights and other rights

FI has policies in place to monitor corporate actions and, if authorized and directed in the applicable investment management agreement or confidential client agreement, ensure the exercise of voting rights.

To the extent FIL is authorized and directed to vote proxies on behalf of a client pursuant to the confidential client agreement, FI, on behalf of FIL, utilizes ISS as a third-party proxy service provider. ISS is one of the largest providers of corporate governance solutions with services including objective governance research and analysis, proxy voting and distribution solutions. When FI votes proxies on behalf of FIL’s clients, FI partners with ISS to evaluate issues and votes with the best interests of FIL’s clients in mind. If a FIL client were to request FIL to vote proxies on behalf of such FIL client a certain way or to apply a specific proxy voting policy, FIL and FI, on behalf of FIL, will do its best to accommodate the request. FI frequently engages with company management on proxy voting issues.

FI’s Proxy Voting Policy is available on request.

FI’s Corporate Actions Elections Policy is available on request.

3.4 How FI, on behalf of FIL’s clients, co-operates with other shareholders

FI recognizes the importance of working together, and FI collaborates with other institutional investors through certain networks and on an ad hoc basis to engage companies when FI believes doing so is likely to advance FIL’s clients’ interests, is consistent with FI’s and FIL’s policies and procedures and is permissible under applicable laws and regulations. FI seeks to have a clear objective for collaborative engagements. As involving multiple parties in an engagement can increase complexities, FI seeks to ensure all collaborative engagements follow the United Nation’s Principles for Responsible Investment’s “4 Cs” for success: commonality, coordination, clarity and clout. FI evaluates collaborative engagements as it would standalone engagements.

3.5 Communication with relevant stakeholders

Neither FIL nor FI systematically communicate with stakeholders of companies regarding the investment decision. However, as part of FI’s due diligence on a company, FI, on behalf of FIL’s clients, may review publications or participate in events that may also be attended by other stakeholders. In addition, FI, on behalf of FIL’s clients, occasionally participates in collective engagements with other shareholders (as described in Section 3.4), which may include representatives from stakeholder groups.

3.6 Conflicts of Interest 

FIL and FI have adopted effective written conflicts of interest policies and have put in place procedures and measures for the prevention or management of conflicts of interest including where such conflicts may arise due to how FI, on behalf of FIL’s clients, engages with companies FIL’s clients are invested in.

4. Disclosure of FIL’s, and FI’s on behalf of FIL, engagement activities

4.1 SRD II requires that FIL either (i) on an annual basis, disclose how this Policy has been implemented, including a general description of voting behaviour, an explanation of the most significant votes and the use of the services of proxy advisors, as well as how FIL, or FI on FIL’s behalf, cast votes in the general meetings of companies in which FIL’s clients hold shares (collectively “Periodic Disclosure”) or (ii) disclose a clear and reasoned explanation why FIL has chosen not to publish such Periodic Disclosure.

4.2 Neither FIL nor FI votes proxies on behalf of FIL’s clients unless an FIL client authorizes and directs FIL to do so and FIL accepts such responsibility. As of the date of this Policy, no FIL clients have provided such authority and direction. Therefore, FIL has no Periodic Disclosure to disclose. Should any FIL clients authorize and direct FIL to vote proxies, and FIL accepts such responsibility, FIL will publicly publish the applicable Periodic Disclosure for such FIL clients.

4.3 If an EU regulated life insurance company or occupational pension scheme (in each case an "Institutional Investor") is an FIL client, such Institutional Investor will be provided at least annually with the specific information prescribed in Luxembourg’s transposition of SRD II.

4.4 Where the information to be disclosed in accordance with Section 4.3 is publicly available, FIL shall not be required to provide that information to the relevant Institutional Investor directly.

5. Review of the Policy 

This Policy will be reviewed and updated on at least an annual basis, and altered from time to time as appropriate. The latest version of this Policy will be available on FIL’s website.