Aviva Investors - Principles for Responsible Investment

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Principle 3 We will seek appropriate disclosure on ESG issues by the entities in which we invest. Principle 3 is about ensuring that information related to ESG issues is disclosed by companies and other entities in your organisation's investment universe. It is closely related to your activities on Principle 1 and Principle 2. This section lists questions regarding: Who seeks ESG disclosure information for your organisation; The level of detail and content that is sought; The information you may be seeking regarding norms, standards, codes of conduct or international initiatives related to RI/ESG. While completing this section you are free to move to other sections of the survey without losing work you have already done. Q 52 Please provide a description of your organisation's approach to this Principle. For example, how does your organisation seek appropriate disclosure on ESG issues by the entities in which it invests Note that this text in addition to being part of the full survey will also be part of the survey's Executive Summary. The Executive Summary is a separate document that will collate the text you provide for each of the introductory sections of the survey (GPS and the six Principles). We actively promote greater corporate accountability on environmental, social and goverance (ESG) issues via enhanced disclosure across a broad range of our assets and at face to face meetings. One distinctive element of our approach is our corporate responsibility disclosure voting. It has been Aviva Investors policy since 2001 to promote increased Corporate Responsibility (CR) reporting via AGM voting. In 2010, this policy was applied to all FTSE 350 Index and EuroFirst 300 Index companies, in addition to selected client portfolios, (a subset of our full governance voting policy). In 2011, this will be extended to the MSCI World Index. The policy states that we expect these companies to disclose information on their exposure to and management of key environmental and social risks. Where companies publish insufficient information, we may abstain or vote against the resolution to adopt the Report and Accounts. As far as we are aware, we were the first institutional investor in the world to adopt such a policy, and it remains a particularly distinctive element of our overall RI strategy. In 2010 Aviva plc introduced a separate advisory vote for the Group CR report. Aviva was the first company in the UK and the first financial institution in the world to take this step. We actively encourage other companies to take their own step in this direction, which we believe will contribute to creating the right kind of discussions within the boardrooms of listed companies around the world, and then between the company and its shareholders. We advocate this in one to one meetings with companies and through our work on the Sustainable Stock Exchanges initiative. Q 53 Who asked for and/or collected from your organisation's investee companies (or other investment entities) information about their ESG policies, practices or performance in 2010 Internal staff Please select all that apply External investment manager(s) External engagement service provider(s) External research providers Brokers / dealers Other please specify: None of the above: Investee companies, or other investment entities, were not asked to provide information about their ESG policies, practices or performance in 2010 (please specify below why not) If investee companies were not asked, please specify why. Copyright ©2011 PRI Association. All rights reserved. page 20 / 30
Q 54 To what extent did you or your external agent(s) seek appropriate disclosure on ESG issues by the investees and, where necessary, encourage investee companies to produce standardised and/or systematic reporting about their ESG policies, practices or performance in 2010 Asset class Listed equity (developed markets) Listed equity (emerging markets) Fixed income sovereign and other noncorporate issuers Fixed income corporate issuers Listed real estate or property Nonlisted real estate or property Please select: "Large", "Moderate", "Small" or "Not at all" Large Small Not at all Moderate Large Large Q 55 In which format or mechanism have you or your third party agents requested reporting on ESG policies, practices or performance Reporting formats Please select all that apply Integrated with regular financial reports Standalone corporate (social) responsibility or sustainability reports Global Reporting Initiative (GRI) Carbon Disclosure Project (CDP) Global Framework for Climate Risk Disclosure Communication on Progress (COP) by the United Nations Global Compact Countrylevel company form of the Extractive Industries Transparency Initiative (EITI) Submission of a tailored survey Other reporting framework by an industry or association please specify: None of the above Q 56 To what extent did you or your third party agents seek information from companies regarding their practices related to norms, standards, codes of conduct or international initiatives/ declarations/ conventions related to ESG issues in 2010 Please select: "Large", "Moderate", "Small" or "Not at all" Please select: Large Copyright ©2011 PRI Association. All rights reserved. page 21 / 30
Page 1 and 2: An investor initiative in partnersh
Page 3 and 4: Q 9 Please provide the following in
Page 5 and 6: Q 12 Do you have a policy or a set
Page 7 and 8: Q 17 Please select any of the follo
Page 9 and 10: Q 19 Please provide a description o
Page 11 and 12: Principle 2 We will be active ow
Page 13 and 14: Q 29 For listed equities, who makes
Page 15 and 16: Q 37 Do you have a written engageme
Page 17 and 18: Q 46 What percentage of engagements
Page 19: Q 50 Please describe your organisat
Page 23 and 24: Principle 4 We will promote acce
Page 25 and 26: Q 64 Please add any overall comment
Page 27 and 28: Q 68 Did your organisation particip
Page 29 and 30: Q 73 Did you disclose your (proxy)

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