Global Value Team Responsible Investment Guidelines

• The Global Value Team defines Responsible Investment (“RI”) as the consideration of financially material Environmental, Social, and Governance (ESG) factors in our investment process alongside more traditional measures.
• As a long-term and engaged owner, the Team seeks to invest selectively in companies with persistent businesses run by management teams focused on creating durable value.
• We believe ongoing discussions with management—including on issues sometimes related to ESG—can be an important part of our assessment of a company which helps us make better informed investment decisions and is consistent with our fiduciary responsibility.
• Consistent with our commitment to these guidelines, First Eagle Investment Management, LLC became a Signatory to the United Nations backed Principles for Responsible Investment (PRI)¹ in 2020.
   

The overarching investment objective of the Global Value team is to earn attractive, real returns for clients while avoiding the permanent impairment of capital across economic cycles. To this end, we seek to invest selectively in companies with persistent businesses, run by management teams focused on creating durable shareholder value, and we do so only at prices we believe are rational.

As patient fundamental investors, we take a holistic approach to analyzing the key factors that may affect the long-term viability of a company’s business model, strategy and financial health. Alongside more traditional investment considerations, this approach also includes assessing material ESG risks and opportunities.

The team takes a qualitative, nuanced, and forward-looking approach to assessing ESG Factors, relying primarily on our proprietary research and complemented by access to reports from third-party data providers. Our analysts evaluate issuers on a case-by-case basis, exercising their best judgment to determine what factors are financially material. Consistent with this approach, the Team does not follow a prescribed internal reporting format.

We believe corporate governance is essential to creating durable value. Accordingly, we typically review companies’ governance practices, policies, and capital allocation decisions. While our analysis emphasizes more traditional governance considerations, we also recognize that a sensitivity to material ESG factors at the management level can contribute to the durability we seek in an investment. We believe good governance also extends to the management of financially material environmental and social risks and opportunities and will consider environmental and social factors that we identify as having the potential to materially impact the operations, performance, and valuation of a company.

To maximize the universe of potential investment opportunities with attractive valuations, we do not apply exclusionary screens to the portfolios we manage unless requested by clients or required by law. In our commitment to helping clients meet their financial and non-financial investment objectives, the Global Value team offers clients the option to establish bespoke ESG guidelines in a separately managed account.

Prior to any investment by the Global Value team all securities are required to be cleared against sanctioned countries lists maintained by the US Office of Foreign Assets and Control, the European Union and the United Nations. After a trade order has been placed, investments are also reviewed by the team for any United Nations Global Compact violations using data provided by a third party².
 

As active investors, we are committed to creating durable value for our clients over the long term through our stewardship activities. These activities include discussions with management and proxy voting.
 

• Discussions with Management
• A strong governance structure gives us confidence that a company is well positioned to maintain its competitive advantages in the face of existing and evolving risks. As such, time with management—to understand their goals, motivations, strategy and performance—is often an important part of our investment process. We seek to build long-term relationships with company management and traditionally express our views privately. This enables us to have constructive discussions with many of the companies in our portfolio on a wide range of issues, including those related to ESG factors. These discussions can help us to better understand a company’s preparedness to manage emerging risks and challenges to its business model, regardless of source. In the Team’s ESG-specific discussions, we typically seek to gain a clearer understanding of a company’s preparedness to address financially material risks and opportunities, known controversies, as well as board oversight mechanisms.
   
• Proxy Voting
• The Global Value team’s proxy-voting policies and procedures are designed to help ensure that all ballots are cast in the best interest of our clients. We strive to vote on all proxy resolutions to the extent practicable. Each vote is evaluated by investment analysts on the basis of its individual merits, using benchmark research provided by the proxy advisory firm, Institutional Shareholder Services. While we typically vote our clients’ shares in line with ISS recommendations, the Team retains the ultimate decision on how to vote our clients’ shares. When more contentious proposals are brought to a proxy vote, we may consult another proxy advisor’s research and/or engage directly with company management to better understand the issues. .
   

The Global Value team includes dedicated ESG and Stewardship professionals. To complement our proprietary bottom-up analysis, we also invest in research and data—including ESG ratings, ESG controversies and climate-risk data from third-party providers-- which helps us monitor portfolio performance on ESG indicators and support client reporting.

First Eagle Investments Management, LLC is also a member of organizations that provide access to insights on policy changes and best practices in Corporate Governance and ESG, including the Council for Institutional Investors (CII), International Corporate Governance Network (ICGN) and Principles of Responsible Investment (PRI). Note, however, that it has not been the firm’s practice to participate in collaborative engagements or lobbying efforts, regardless of membership.
 

The Global Value team seeks to be transparent in our approach to incorporating ESG considerations into our investment processes. We update our Responsible Investment Guidelines periodically, and we also provide clients with greater detail about our processes upon request.
 

The Global Value team is responsible for the oversight of these guidelines and their application in a manner we believe to be appropriate and practicable considering the nature of each security issuer, our investment strategies, and the best interests of our clients. These responsibilities are also supported by other First Eagle employees and third-party providers. The firm’s Legal and Compliance Department works closely with the Global Value team and with the other departments of the firm to identify the activities described herein that require external reporting and/or internal controls.

1.These Responsible Investment Guidelines apply to the Team’s investments in equity securities and also, in part, to other asset classes where practical. These Guidelines apply July 15, 2024.

2.We use third party screens to identify publicly traded companies and fixed income issuers involved in controversies that may constitute a breach of these global norms and conventions. The UN Global Compact screen includes severe controversies relating to human rights, labor rights, environment, and economic & business issues.