The integration of a client’s values and preference for ESG factors is an extension of our long-standing investment management process, which starts with understanding what is important to our clients. We seek to help our clients meet their goals and objectives while following the core tenets of portfolio management, including strategic asset allocation, diversification and cost. The focus on these tenets is considered and balanced with a client’s desire to incorporate their values into their investment portfolios.

In order to integrate responsible investing options into our platform, we have implemented a process to identify and categorize ESG investment solutions. We utilize third-party ESG data to assess the characteristics—financial and non-financial—of investment managers and third-party solutions. We conduct an annual survey of our investment managers to learn about their ESG processes, while also engaging with firms to understand their commitment to ESG. Through our interviews with investment managers and using resources like Sustainalytics, Bloomberg and Morningstar, we evaluate such factors as how managers engage with the companies they invest in, how they vote proxies, and whether that meets our criteria to be considered an ESG or values-based investing solution. This information, as well as performance analysis, is shared annually with our management-level Investment Committee, which oversees and has managerial responsibility for our ESG investment solutions.

We offer a platform of solutions to help our clients meet their ESG-related goals and objectives including:

• ESG Integration – strategies or investment firms may employ a positive tilt toward companies with positive ESG characteristics and exclude others based on specific ESG criteria, or seek out companies considered to be ESG leaders within their respective sectors and industries. Others may integrate ESG criteria at the sector, industry or company level to determine the allocations that might produce the best long-term risk and return characteristics for their portfolios.
• Impact Investing – this approach generally allows the investor to target projects, initiatives and investments that seek to achieve specific environmental or social benefits, while also producing a return to the investor.
• ESG Impact Portfolios offer a multi-asset solution that uses the company’s tactical and strategic allocation process while selecting funds that primarily invest in companies that strive to balance their responsibilities to shareholders and global stakeholders. The portfolio is a solution for investors seeking a positive impact and a competitive financial return.
• Through the company’s investment management activities, additional investments in alternative energy have been a natural extension given the expertise in the energy sector and overall client interest in diversifying energy exposure. Investments in alternative and renewable energy have occurred through traditional equity investments and alternative investment allocations among some client portfolios.

Beginning in 2023, we will offer annual training to our team members within our wealth management division to educate them on responsible investing and the related ways we can serve clients, most of which is by focusing on incorporating their values into their investment portfolios.

Over the past year, we have also put in place a mechanism to receive and investigate any potential complaints related to responsible investing and to implement any corrective action that could result.

Related documents

Standards of Conduct
The Audit Committee of the Board of Directors annually reviews and approves the company’s Standards of Conduct on which employees are annually trained and attest to. Each member of the Board of Directors takes an annual Oath of Office prescribed by the Office of the Comptroller of the Currency (OCC) and is bound by the company’s Code of Ethics.

Proxy Statement
The company’s annual proxy statement identifies responsibilities of board committees.

10-K
The company’s 10-K reviews a wide array of company performance factors, including any monetary losses as a result of legal proceedings associated with fraud, insider trading, anti-trust, anti-competitive behavior, market manipulation, malpractice, or other related financial industry laws or regulations.