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Outlook Macro and market ESG Impact Stewardship Sustainable investing Article

2022 ESG & Sustainability Outlook

Multiple authors
December 2021
2022-12-31
Archived info
Archived pieces remain available on the site. Please consider the publish date while reading these older pieces.
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The views expressed are those of the author at the time of writing. Other teams may hold different views and make different investment decisions. The value of your investment may become worth more or less than at the time of original investment. While any third-party data used is considered reliable, its accuracy is not guaranteed. For professional, institutional, or accredited investors only.

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      Introduction

      Taking action: How your organization can build climate change resilience in 2022

      In a recent speech, Janet Yellen, US Treasury Secretary and former chair of the US Federal Reserve, addressed a global audience of finance ministers, policymakers, and investors in Glasgow ahead of the UN Climate Conference of the Parties (COP26). Ms. Yellen said, “The flow of capital from carbon-intensive to carbon-neutral investments is the most dramatic and predictable economic shift in human history.” As investors and fiduciaries of our clients’ capital, we believe we must understand this shift in order to fulfill our primary mission: exceed our clients’ investment objectives.

      Three years ago, we entered into a research partnership with Woodwell Climate Research Center to bridge the knowledge gap between climate science and finance. Our goal then, as now, is to integrate climate data and insights into our investment approach to produce better financial outcomes for our clients. While we continue to expand our climate investing offerings, our goal is not only to provide climate solutions for our clients, but also to incorporate our growing knowledge of climate change across our investment and operational platform.

      Please see our 2022 Climate Investing Outlook for insights from our Climate Research and Investment teams.

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      Key insights

      Through our ongoing research with Woodwell, we have gained several key insights:   

      • First, physical climate risks like heat, drought, floods, wildfires, hurricanes, water scarcity, and sea-level rise are driving this historic economic shift toward a low-carbon future.
      • Second, climate risks are not priced into capital markets. This is creating market inefficiency and broader potential risk.
      • Third, society’s awareness of and, therefore, resilience to physical climate risks is low.
      • And fourth, solutions that help society adapt to and mitigate the effects of climate change are essential to ensure a sustainable economy.

      These lessons continue to influence our approach to climate change. In 2020, we published our Physical Risks of Climate Change (P-ROCC) framework designed to help companies identify, analyze, and disclose their exposure to physical climate risks. In 2021, we expanded this to P-ROCC 2.0, calling for companies to disclose physical location data, which helps investors better assess their risks and discuss building operational resilience.

      We have also communicated with the US Securities and Exchange Commission (SEC) following its request for input on climate disclosures for US-listed issuers. In a public letter and subsequent meetings, we emphasized market inefficiencies resulting from a lack of corporate climate transparency and expressed the need for consistent, standardized disclosure of Scope 1, 2, and 3 greenhouse gas (GHG) emissions and physical location data. We expect the SEC to release a proposed rule early in 2022. 

      Through our efforts, we hope to help broaden awareness of physical climate risks and the need for markets to price those risks appropriately.

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      Need for climate change mitigation and adaptation

      The world is well on the way to establishing a policy environment supportive of efforts to reduce emissions and stem global warming. While these mitigation measures may help limit the worst long-term effects of climate change, climate impact over the next 30 years is unavoidable, given the half-life of GHGs already in the atmosphere. Society simply has no choice but to adapt to a changing climate. Companies that recognize and address physical risks may see their costs of capital decline and valuations rise. Municipalities that do the same may see bond rates fall and tax bases expand. Companies and issuers that develop adaptation and mitigation solutions should see strong demand and growing markets. On the other hand, entities that prove slow to build resiliency may suffer the downside of those equations.

      We believe the low-carbon economic shift will accelerate as more people demand action from companies and policymakers. As founding members of the Net Zero Asset Managers initiative (NZAMI), we are committed to helping our clients navigate the transition. Through our participation, we aim to further industry best practices for target setting and measurement to ensure real-world emissions reductions.

      We have come to appreciate that while buying and selling securities based on emissions can change the reported carbon footprint of an investment portfolio, it does not necessarily reduce our clients’ exposure to climate risks. Only by helping companies we invest in adopt credible, achievable strategies for lowering their carbon footprint can we affect real emissions reductions. Moreover, by encouraging issuers to adopt transition plans with science-based targets, we believe we can decarbonize portfolios from the bottom up and more effectively insulate our clients’ assets from climate risks over time.  

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      What you can do in 2022

      To help your organization build climate preparedness, you may want to consider applying some of our lessons learned to your investment strategy:

      • Learn about climate change investing

        — Ask external portfolio managers how they are considering physical risks of climate change. What data do they use, and how do they engage with companies?

        — If you have internal portfolio management, consider using P-ROCC or your own climate framework during engagements

      • Communicate with policymakers

        — Ask regulators to request that companies disclose emissions and      location data

        — Encourage regulators to align frameworks with others being developed around the world

      • Establish climate-aware investment portfolios

        — Options increasingly include a range of asset classes, including equities, fixed income, real estate, and alternatives

      • Consider allocating assets to portfolios that fund climate solutions
      • Set a net-zero goal and work with your investment managers to implement it

      We look forward to building momentum in 2022 around climate investing and climate engagement. We continue to broaden our research with Woodwell and to engage with companies, clients, regulators, and industry groups on the many ways that we, as active investment managers, can reduce the real-world risks of climate change while strengthening capital markets. As an African proverb says, “If you want to go fast, go alone, if you want to go far, go together.” We hope by sharing our insights you will also feel inspired to take action on climate change to ensure a sustainable, low-carbon future.

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       Toward carbon neutrality in 2022

      Wellington has committed to being carbon neutral in our operations by the end of 2022. To achieve that goal, we are taking a multifaceted approach that includes prioritizing direct reduction of our activities that generate GHG emissions, sourcing renewables for our purchased electricity needs, and purchasing high-quality carbon offsets for our remaining emissions. I invite you to learn more about our carbon neutrality goal and approach to carbon offsets here.

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      Istrat insights

      Sustainable thematic investing: Climate action and economic development

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      Nearly two years of a global pandemic, sluggish growth, and record climate-related disasters have exposed the need to narrow economic inequities and manage our natural resources in ways that ensure the well-being of future generations and the environment. The global focus on sustainability is accelerating thematic shifts, creating structural tailwinds, and driving investment opportunities across sectors. We view sustainability-aligned themes as multi-decade opportunities that are just beginning to gain momentum. While we accept that there may be some volatility in these areas in 2022, we will continue to combine our top-down thematic and bottom-up fundamental process to stock selection.

      In 2022, our attention will be on companies addressing some of the world’s most pressing needs, including climate action and sustainable economic development, notably in the themes of education and enterprise intelligence. We anticipate growing demand for solutions and already see a range of preemptive investment opportunities.

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      Climate action

      As society increasingly recognizes the need to reduce carbon emissions to slow the effects of climate change and prepare for more severe weather events, climate mitigation and adaptation solutions should see rising demand. Following the UN Climate Change Conference of the Parties (COP26) in Glasgow this year, it is clear that most major economies are committed to taking action on climate. Policy tailwinds are providing significant support for companies focused on the energy transition and related climate mitigation solutions. In countries where government support for climate action is weaker, corporates and consumers are stepping in to incentivize change. Companies signing on to the Science Based Targets initiative (SBTi) represent approximately 36% of the MSCI All Country World Index’s market cap, up from 23% at the end of 2020.1 We see opportunities in renewable energy, power grid infrastructure, electric vehicles, and battery manufacturers.

      As for adaptation, Wellington’s climate research, conducted in collaboration with Woodwell Climate Research Center, has confirmed that many effects of climate change are irreversible, regardless of mitigation efforts. Existing atmospheric greenhouse gasses increase the risk of worsening climate events in many parts of the world. Investment opportunities aligned with helping society adapt and protect itself from climate change include engineering companies specializing in infrastructure resilience, as well as heating, ventilation, air conditioning, and water treatment businesses.

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      Sustainable development

      Beyond climate-related themes, we see attractive opportunities aligned with sustainable economic development. Two of our long-term, high-conviction themes are education and enterprise intelligence. Throughout 2021, the market continued to concentrate on lingering COVID-19 headwinds, geopolitical tensions, and a shifting regulatory environment. Moving through 2022, as the world gains greater clarity and confidence that the pandemic is behind us, we believe the market will begin to appreciate opportunities in education and jobs training, technology and services, and specialty (education-related) real estate investment trusts (REITs).

      Within the enterprise intelligence theme, we are looking at companies whose tools and technologies improve data storage and security, automate manual processes, and enhance operational and labor efficiencies. The pandemic accelerated and expanded reliance on digital technologies, and we believe enterprise solutions should benefit from this structural tailwind. Within this theme, we are targeting enterprise software, cybersecurity, and digital platform companies.

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      Near-term risks on our radar

      While our conviction in the long-term thematic opportunity is high, we are cognizant of the need for caution in the near term. The market’s recent increased support for sustainability-oriented themes has helped boost performance in these areas over the past 18 months. Apart from education, which is a decidedly contrarian idea, a sustainability “beta” has raised valuations for a relatively broad set of sustainable companies. We intend to proceed with caution and reassess the fundamental case for any investment in this space. In our process, we aim to examine the purity of a thematic exposure — what portion of a company’s revenue is aligned with a given theme, for example — and use exhaustive bottom-up research to identify companies with the potential to sustain growth and generate attractive returns on investment, even in the event of a temporary pullback in sustainability-related themes in 2022.

      1sciencebasedtargets.org, as of 1 November 2021.

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      Impact Insights

      Impact investing: Seeking solutions that help the world recover

      In 2022, research across our 11 impact themes continues with a particular focus on impact opportunities in financial inclusion, digital divide, and health. As always, we aim to invest in companies and issuers whose core goods and services address the world’s biggest social and environmental challenges. The COVID-19 pandemic and ensuing economic slowdown exacerbated fundamental socioeconomic inequities and heightened the need for financial-, digital-, and health-related solutions. In the coming year, we will also examine several themes through the lens of climate change, noting the accelerating demand for climate adaptation and mitigation, as well as the growing overlap between climate and impact investing solutions.

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      Financial inclusion

      Many households and small businesses are struggling to recover economically or avoid slipping further behind. Access to affordable financial products and services, including technology, is vital for greater financial inclusion. For 2022, we have identified impact opportunities in companies and issuers that support small businesses and entrepreneurs, especially those in emerging markets who may find it difficult to access financial resources from standard lenders or other providers.

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      Access to affordable financial products and services, including technology, is vital for greater financial inclusion.

      .

      One company in Puerto Rico expands financial inclusion by providing financial services to local individuals and small business owners. The island has been devastated by natural disasters and persistent economic recession. We believe its recovery and rebuilding process requires steady, broad-based access to financial services. We have also identified companies that support underserved and underbanked populations in emerging and frontier economies, including a financial services group whose products help low-income communities in Africa, where the cost of insurance to cover basic needs like funeral expenses can wipe out family savings. In fixed income, we have identified an issuer whose financial technology solutions enable and lower the costs of e-commerce for small businesses in Brazil. The company’s platform facilitates its customers’ ability to scale by reaching new markets and pursuing growth opportunities.

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      Digital divide

      Reliable digital connectivity has become critical for social and economic stability, yet digital inequality across developed and emerging markets continues to widen. We anticipate significant long-term demand for technologies that support communication and connectivity, particularly for education and job training, financial services, and health care. This theme also allows us to gain exposure to another critical sustainability issue: evolving electric grids to be more energy efficient. We are invested in a bond issued by a Costa Rican telecommunications and energy company, for example, whose coupon rate is linked to the installation of smart electricity meters. We believe this company plays an important role in expanding information and helping rural communities participate in the digital economy, while reducing the energy required to do so.

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      Health

      The pandemic revealed a widespread lack of access to affordable care, pervasive inefficiencies in health service and delivery, and chronic underinvestment in health care infrastructure. As societies appreciate the importance of narrowing these gaps, impact companies are stepping up to fill them. Across emerging markets, we see opportunities for the vertical integration of health care services, which tends to improve the quality of care. In Brazil, we have an opportunity to invest in a vertically integrated health services company that aims to improve access to quality care for lower-income populations. The company’s networks of clinics and hospitals provide basic services, including maternity and dental care in and around São Paulo. In India, we are exploring an impact opportunity in a brick-and-mortar health services company that is expanding its telemedicine business to better serve rural communities.

      Vertical integration has contributed to rising health care inflation in some emerging markets. We will continue to engage with companies to understand how they manage and mitigate the effects of rising health care prices on consumers. In 2022, many countries will continue to grapple with the costs associated with containing the spread of COVID-19, along with the inflationary pressures of a rebound in demand for elective care.

      New models for health care provision fit well in our health theme and meet our standard for impact. In the US, we have identified solutions that empower local physicians to deliver primary care as a first line of defense for disease prevention, helping to improve outcomes and lower costs for patients. In China and other emerging markets where spending on health care infrastructure has historically been low, we believe technologies that allow elderly or rural patients to access a health care provider virtually can significantly expand access and lead to better health outcomes.

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      Climate change: Impact opportunities span multiple themes

      Research conducted by Wellington’s Climate Research Team and our climate science partners at Woodwell Climate Research Center confirms the need for governments and businesses to improve climate resiliency. The necessity for climate solutions that help society adapt and protect lives and property from climate events crosses several of our impact themes. Within safety and security, we have identified innovative companies that manufacture impact-resistant windows and doors developed to withstand severe weather conditions. We have also identified green bonds from issuers whose projects primarily contribute to affordable housing, clean water and sanitation, and financial inclusion projects. Investing in these issuances enables us to support issuers’ ambitions to improve energy and water efficiency, employ sustainable building materials, and otherwise facilitate the transition to a low-carbon economy.

      In 2022, we will continue to set a high bar for verifying the materiality and credibility of sustainability-oriented structured-finance solutions — and their sustainability performance targets. We aim to invest in issuances that incentivize issuers to improve their sustainability profiles. We have observed greater focus from companies and issuers on setting targets with sustainability metrics. This disclosure provides us with opportunities to engage in best practices with respect to reporting and tracking key issues like decarbonization efforts and supply-chain transparency. We will also continue to engage with boards and management teams to establish metrics that demonstrate positive social and environmental impact.

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      Stewardship Insights

      Stewardship investing: Talent, supply-chain, and environmental management

      We aim to invest in companies that lead from a position of strength, with skilled management and empowered boards who consider the interests of all stakeholders. Stewardship often requires making difficult trade-offs that affect stakeholders differently. As we emerge from the COVID-19 pandemic, we believe it is more critical than ever for companies to balance their pursuit of profits with their impact on people and the planet. Amid increasing calls to action for firms to be better stewards of talent, supply chains, and the environment (particularly regarding biodiversity), we plan to focus on these issues in the coming year.

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      Talent management

      In our view, a positive environment for talent can influence productivity, innovation, reputation, and loyalty. Today, rising inflation and labor shortages are driving wages up, making talent management more important than ever. Over the coming year, we expect to allocate more of our research and engagement time to talent and culture, as these pressures are unlikely to abate. Which companies can attract and retain top talent? Which are building diverse, adaptable workforces? Does a company have a culture of innovation? Talent management is especially important in sectors like health care, where continuous scientific innovation and knowledge of prior developments are keys to developing long-cycle advantages. Similarly, technology companies must access and retain workers with cutting-edge software and programming skills in order to stay competitive.

      While highly skilled workers have typically been treated well via equity-based compensation, less skilled workers have not benefited from the growing economic pie in the same way. However, today’s tight labor markets help give lower-wage stakeholders a voice to push for more equitable treatment. Even companies with what we consider to be great cultures and fair compensation plans are seeing more active union activity and pressure for pay rises. We will continue to ask companies how they are managing talent-related pressures, and we generally favor purpose-driven businesses with talent-focused cultures. We will balance our engagements with fundamental research, including on employee reviews and CEO approval ratings.

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      Supply-chain accountability

      The market’s current concerns about supply-chain disruption are very short term, focused on temporary low capacity, labor shortages, and lingering COVID-related restrictions. Within the next year, we expect ships will start moving out of China again, backlogs at ports will clear, plane-belly capacity will recover as travel restrictions ease, and labor conditions will rebalance. In our view, the real challenge is how well companies understand and manage their entire supply chain — through to source materials — over the long term. This is another area of focus for us in 2022.

      Because supply chains are often complex and opaque, building resilience to avoid interruptions requires constant oversight and investment and a long-term mindset. We want companies to focus not only on dependable logistics and inventory levels, but also on labor-related risks such as exploitation and on climate transition- and physical-risk exposures. For example, we work with companies to understand how they partner with suppliers to help them source renewable energy to reduce their carbon footprint. We also engage on social risks, holding companies to account for their entire value chain.

      While companies are often far removed from raw materials sourcing and other early supply-chain links, labor abuses at this end of the value chain can be rampant. Traceability is at the core of strong supply-chain stewardship: If you track it, you can manage it. When it comes to the risk of human exploitation, we want companies to demonstrate decisive remediation, addressing thorny issues like modern slavery when and where they arise. Mitigating these risks can have a positive financial impact for a company by reducing disruptions, fines, and other unexpected costs.

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      We want companies to focus not only on dependable logistics and inventory levels, but also on labor-related risks such as exploitation, and on climate transition- and physical-risk exposures.

      .

      Biodiversity engagement

      Environmental impact and climate concerns are also a focus for 2022. In particular, we expect to do more work on the issue of biodiversity. It is increasingly clear that companies will be held to account for their impact on local ecosystems. Raw materials extraction and cultivation and midstream industrial processes exacerbate the adverse effects of climate change. Habitat loss, including deforestation for the sourcing of lumber and other materials, is a major contributor to biodiversity degradation. Society must address the rapid decline of biodiversity to preserve longer-term access to food, clean air and water, and availability of raw materials.

      We ask the boards and management teams of our portfolio companies — regardless of their direct environmental footprints — to embrace more environmentally sustainable practices as a means of protecting shareholder value. We want evidence that environmental externalities are factored into capital allocation decisions. For example, we look for leadership on supplier practices and sustainable-product innovation. This might mean reduced use of toxic substances in production processes, a commitment to environmental-impact assessments for future projects, or greater accountability for waterway pollution, to name a few.

      Finally, we believe companies that have embraced science-based targets to reduce emissions in line with the Paris Agreement should also consider how they can commit to science-based targets that align with the Biological Diversity’s Post-2020 Framework. In the coming year, we will look to engage in two-way dialogue on how companies might shape these commitments.

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      Final thoughts for 2022

      Our conversations with portfolio companies continue to help us to better understand the challenges they face in managing talent, supply-chain, and environmental challenges. While these efforts can be costly and require multiyear commitments, when companies operate from a position of strength and can reinvest high returns on capital in all stakeholders, we believe they can improve resilience far into the future.

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      Authored by
      cromwell-wendy-316x316
      Wendy Cromwell, CFA
      Head of Sustainable Investment
      Boston
      dunne-daire-5031-648x648
      Dáire Dunne, CFA
      Head of Next Generation Thematic
      Singapore
      Campe Goodman
      Campe Goodman, CFA
      Fixed Income Portfolio Manager
      Boston
      Tara Stilwell
      Tara Stilwell, CFA
      Equity Portfolio Manager
      Boston
      Liliana Castillo Dearth
      Liliana Dearth
      Equity Portfolio Manager
      Singapore
      courtines-yolanda-4205-648x648
      Yolanda Courtines, CFA
      Equity Portfolio Manager
      London
      Mark Mandel
      Mark Mandel, CFA
      Equity Portfolio Manager
      Boston

      This is an excerpt from our 2022 Investment Outlook, in which specialists from across our investment platform share insights on the economic and market forces that we expect to influence portfolios in the year to come.

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      9.Risk Warnings: There are significant risks associated with an investment in any of the Funds.  Investment in the Funds is intended only for those investors who can accept the risks associated with such an investment (including the risk of a complete loss of investment) and you should ensure that you have fully understood such risks before taking any decision to invest.

      Investments in the Funds are neither insured nor guaranteed by any investor compensation scheme and are not deposits or obligations of, or guaranteed by, any entity within the Wellington Management group.

      These Terms do not represent a complete statement of the risk factors associated with an investment in the Funds.  The offering documents for each Fund contain risk warnings which are specific to the relevant Fund.  You should consider these risk warnings carefully and take appropriate investment advice before taking any decision to invest. 

      10.Offering Documents: The terms of any investment in a Fund are governed by the documents establishing such terms.  An application for interests in any of the Funds should only be made having fully and carefully read the offering documents, which are the relevant prospectus, the latest financial reports and any other offering documents for the relevant Fund which are available on this Website and upon request from the fund representative in your jurisdiction and specified in the prospectus for the relevant Fund.

      It is your responsibility to use the offering documents and by making an application to invest in a Fund you will represent that you have read the prospectus for the relevant Fund, the appropriate key investor document for the Fund and any other applicable offering document and will agree to be bound by its contents.

      11.Information on this Website: This Website, and the information on it, are provided for information purposes only and do not constitute an invitation, offer or solicitation to engage in any investment activity including to buy, hold or sell any investment including any interests in the Funds.

      The information on this Website is provided in good faith and reasonable care has been taken to ensure that such information is accurate, current and fit for its intended purpose.  To the extent that any information on this Website relates to a third party, this information has been provided by that third party and is the sole responsibility of such third party and, as such, Wellington Management and its affiliates accept no liability for such information.  No representation or warranty of any kind regarding the accuracy, adequacy, validity, completeness or timeliness of the information on this Website or the error-free use of this Website is given and, to the extent permitted by applicable laws, no liability is accepted for the accuracy or completeness of such information.  No warranty of any kind, express or implied, including but not limited to the warranties of non-infringement of third-party rights, title, merchantability, fitness for a particular purpose, and freedom from computer virus is given in conjunction with the information, materials, products, and services on the Website. Any views expressed herein are those of the author(s), are based on available information, and are subject to change without notice. Individual portfolio management teams may hold different views and may make different investment decisions for different clients.  Wellington Management does not warrant that the Website will meet your needs. You agree to assume the entire risk as to your use of the Website. Any person who acts upon, or changes his investment position in reliance on information contained on this Website, does so entirely at his own risk.  In the event of any inconsistency between the information on this Website and the terms of the relevant offering documents, the terms of the offering document shall prevail.

      Information posted on this Website is current only as at the date it is first posted and may no longer be true or complete when viewed by you.  All content on the Website is subject to modification from time to time without notice.  Please contact Wellington Management (using the details in the “Contact Us” section below) for further information regarding the validity of any information contained on this Website.

      This Website and most of the documentation contained within it is provided in the English language and you represent and warrant that you understand the English language.

      12.Conflicts of interest: Wellington Management, its affiliates and their directors, officers, employees or clients may have or have had interests or long or short positions in any investment product or other financial instruments underlying any investment product referred to on this Website and may at any time make purchases and/or sales in them as principal or agent. In addition, Wellington Management and/or its affiliates may act or have acted as market maker in any investment product, or financial instruments underlying such investment product or entered into an arrangement to hedge the market risk associated with the investment products. The Wellington Management group has conflicts of interest policies in place which specify the procedures that they follow and the measures that they have adopted in order to avoid such conflicts or to manage such conflicts in a way that ensures fair treatment for

      13.Monetary benefits: You agree that we may, to the extent permitted by applicable laws and regulations, share charges or commission with affiliates of Wellington Management or other third parties, or receive remuneration from them, in respect of transactions you carry out in relation to the Funds described on this Website. Where relevant, we may disclose such arrangements to you.  Details of any such arrangements are available on request.

      14.Liability: No warranty is given that the contents of this Website are compatible with all computer systems or browsers or that this Website shall be available on an uninterrupted basis.

      The internet is not a completely reliable transmission medium and none of the Funds, Wellington Management or any of its affiliates accept any liability for any data transmission errors such as data loss or damage or alteration of any kind or for the security or confidentiality of information transmitted across the internet to or from the Funds, Wellington Management or any of its affiliates.  Any such transmission of information is entirely at your own risk and any material downloaded from this Website is downloaded at your own risk.

      The information on this Website is provided “as is” and “as available”.  To the extent permitted by law, no guarantee or representation, express or implied, is made as to the accuracy, validity, timeliness, completeness or continued availability of any information made available on the Website. The Funds, Wellington Management, its affiliates and each of their directors, officers, employees and/or agents expressly exclude all conditions, warranties, representations, and other terms which might otherwise be implied by statute, common law or the law of equity to the fullest extent permitted by applicable law or regulation.

      In no event will the Funds, Wellington Management, or any of its affiliates be liable to any person for any direct, indirect, special or consequential damages, losses or liabilities arising out of any use of, or inability to use, this Website or the information contained on it including, without limitation, lost profits, business interruption, any failure of performance, error, omission, interruption, defect, delay in operation or transmission, computer virus, line or system failure, loss of programs or data on your equipment or otherwise, even if the Funds,   Wellington Management or its affiliates is expressly advised of the possibility or likelihood of such damages, losses or liabilities, unless such damages, losses or liabilities are due to the Funds’, Wellington Management’s or its affiliates’ negligence, wilful default, fraud or material breach of the Funds’, Wellington Management’s or its affiliates’ obligations under applicable law or regulation.

      This does not affect the liability of the Funds, Wellington Management, or its affiliates for any loss or damage which cannot be excluded or limited under applicable law.

      15.Indemnification: As a condition of your use of the Website, you agree to indemnify and hold the Funds, Wellington Management, and its affiliates, and their respective partners, directors, employees, and agents harmless from and against any and all claims, losses, liability, costs, and expenses (including but not limited to legal fees) arising from your use of the Website or from your violation of these Terms, unless such claims, losses, liability, costs or expenses are due to the Funds’, Wellington Management’s or its affiliates’ negligence, wilful default, fraud or material breach of the Funds’, Wellington Management’s or its affiliates’ obligations under applicable law or regulation.

      16.Intellectual Property: The entire content of this Website is subject to copyright with all rights reserved. All materials on this Website are owned or licensed by the Funds, Wellington Management, its affiliates and/or its third-party providers and are protected by UK and international intellectual property laws. Unless otherwise indicated, all service marks, trademarks, and logos appearing on this Website are the exclusive property of the Wellington Management group. You may not copy, display, distribute, download, license, modify, publish, repost, reproduce, sell, transmit, use to create a derivative work, or otherwise use for public or commercial purposes the content of this Website without the prior written permission of Wellington Management.

      17.Privacy: Please see our privacy notice which is contained on this Website for information about how the Wellington Management group protects your personal data, including personal data collected through this Website.

      18.Cookies: When you use this Website, Wellington Management group may place cookies on your device. For further details about what cookies are and how Wellington Management group uses them please see our Cookies and Tracking Notice.

      19.Your use of this Website: You must not use this Website (or permit or procure others to use it) as follows:

      • for any unlawful, improper or illegal purpose or activity;
      • to communicate or receive information that is obscene, indecent, pornographic, sadistic, cruel, or racist in content, of a sexually explicit or graphic nature, which promotes or incites discrimination, hatred or racism or which might be legally actionable for any reason;
      • in a manner intended to threaten, harass, or intimidate;
      • to violate Wellington Management’s or any third party’s copyright, trademark, proprietary or other intellectual property rights;
      • to damage Wellington Management’s name or reputation or that of Wellington Management’s affiliated companies or any third parties;
      • to impersonate any of Wellington Management’s employees or other person or use a false name while using this Website or implying an association with Wellington Management;
      • to penetrate Wellington Management’s security measures or other entities’ systems (“hacking”);
      • to transmit unsolicited voluminous emails (for example, spamming) or to intercept, interfere with or redirect email intended for others using this Website;
      • to generate excessive amounts of internet traffic, to interfere with Wellington Management’s network or other’s use of this Website or to engage in activities designed to, or having the effect of, degrading or denying service to other users of this Website or others;
      • to introduce viruses, worms, harmful code and/or Trojan horses onto the internet or into this Website or any other entity’s systems and it is your responsibility to ensure that whatever you download or select for your use from this Website is free from such items;
      • to post or transmit information that is defamatory, fraudulent or deceptive including, but not limited to, scams such as “make-money-fast” schemes or “pyramid/chain” letters; and/or
      • to transmit confidential or proprietary information, except solely at your own risk.

      20.Linked Websites: Links to websites operated by third parties are provided for information only and do not constitute any form of advice, endorsement or recommendation of such websites or the material on them.  Wellington Management accepts no responsibility for information contained on any other sites which can be accessed by hypertext link from this Website or for these sites not being available at all times.  Wellington Management has not reviewed, and will not review or update, such websites or information and any use that you make of such websites and information is at your own risk.  Please note that when you click on any external site hypertext link you will leave this Website. You should review the privacy statements of such websites before you provide any personal or confidential information.

      21.Website Security and Restrictions on Use: As a condition to your use of this Website, you agree that you will not, and you will not take any action intended to: (i) access data that is not intended for you; (ii) invade the privacy of, obtain the identity of, or obtain any personal information about any other user of this Website; (iii) probe, scan, or test the vulnerability of this Website or Wellington Management’s network or breach security or authentication measures without proper authorisation; (iv) attempt to interfere with service to any user, host, or network or otherwise attempt to disrupt our business; or (v) send unsolicited mail, including promotions and/or advertising of products and services. Unauthorised use of the Website, including but not limited to unauthorised entry into Wellington Management’s systems or misuse of any information posted to a web site, is strictly prohibited.

      22.Amendment: Wellington Management may delete or make changes to these Terms and to the information contained on this Website at any time.  Where such amendments are made, you will be required to accept any such changes in order and prior to continue to use the Website.  If you do not accept such revised Terms, you may no longer be able to access this Website.

      If any provision of these Terms is found by any court or authority of competent jurisdiction to be illegal, void or invalid under the laws of any jurisdiction, the legality, validity or enforceability of the remainder of these Terms in that jurisdiction shall not be affected and the legality, validity and enforceability of the whole of these Terms in any other jurisdiction shall not be affected.

      23.Third Parties: The Funds, Wellington Management, and its affiliates shall have the benefit of the rights conferred on them by these Terms but otherwise no person who is not a party to these Terms may enforce its terms under the Contracts (Rights of Third Parties) Act 1999.

      24.Applicable Law: These Terms and any non-contractual obligations arising from or connected with them shall be governed by, and these Terms shall be construed in accordance with, the laws of England and Wales.

      25.Jurisdiction: You agree that the English courts shall have exclusive jurisdiction in relation to any legal action or proceedings arising out of or in connection with these Terms (whether arising out of or in connection with contractual or non-contractual obligations) (“Proceedings”) and waive any objection to Proceedings in such courts on the grounds of venue or on the grounds that Proceedings have been brought in an inappropriate forum.  You further agree that this paragraph operates for the benefit of the Funds, or Wellington Management and accordingly the Funds, or Wellington Management shall be entitled to take Proceedings in any other court or courts having jurisdiction.

      26.About Wellington Management International Limited: Wellington Management International Limited is authorised and regulated by the Financial Conduct Authority of the United Kingdom and is entered on the register maintained by the Financial Conduct Authority and the Prudential Regulation Authority (Reference number: 208573). Its registered office is at Cardinal Place, 80 Victoria Street, London SW1E 5JL, United Kingdom and its VAT number is GB420309205. Wellington Management International Limited is an appointed distributor to the Funds.

      27.Contact Us: If you have any enquiries in relation to this Website or the information on it, please contact Wellington at infofunds@wellington.com

      Effective as of 25/05/2018

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