Our Stewardship Approach to the Russian Invasion of Ukraine

Following Russia’s invasion of Ukraine on February 24, 2022, State Street Global Advisors has taken decisive action to condemn Russian aggression, to comply with the developing regulatory landscape, and to provide clients and stakeholders with our perspectives on investing in impacted markets.

As stewards of long-term capital with a global footprint, we are aware of the financial risks that the Russia-Ukraine War presents to our portfolio. As such, we have outlined our approach to stewardship in the context of global conflicts.

In this instance, we have identified holdings in our portfolio in both Russia and Ukraine that may be impacted by the invasion, and that either (i) have continued or recently halted their local business operations, and/or (ii) have not provided public disclosure on their response to the conflict. These holdings may include companies that generate significant revenue from these markets, have multiple Russian and/or Ukrainian subsidiaries, employ local workforces, engage in local joint ventures and partnerships, and/or otherwise have meaningful exposure to the conflict. The Asset Stewardship team will:

• Request engagements with companies with relevant exposure to (but not domiciled in) Russia in order to understand how these companies are managing the regulatory, reputational, and human rights-related risks of operating in the region; and
• Request engagements with companies with relevant exposure to Ukraine with the goal of understanding how these companies are managing risks related to disruptions in the supply chain as well as human capital management.

We expect boards and management teams of impacted companies to take meaningful action to mitigate relevant risks, to provide robust board oversight of these efforts, and to publicly disclose relevant information. Our objectives in these engagements will be to understand whether companies are aligned with these expectations, and to encourage greater alignment as needed.

State Street Global Advisors will not engage with Russian-domiciled companies during this time, and we will not vote at Russian-domiciled shareholder meetings. We believe this to be in the best interest of our clients due to the lack of quality information available to investors and the considerable reputational and regulatory risks to our clients. Additionally, our team will monitor impacted companies domiciled outside Russia with material exposure to the Russian invasion of Ukraine and consider using our proxy vote to hold boards accountable for insufficient oversight of relevant risks, in line with our existing expectations for directors.

Against the backdrop of a grave humanitarian crisis, the Asset Stewardship Team will proactively manage emerging financial risks to our portfolio. We will pursue engagements with impacted companies (excluding those domiciled in Russia) in an effort to ensure our portfolio can continue to generate long-term value for our clients.