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 manager selection. 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 includes strategies or investment firms that 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.
• 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 both 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 to diversify energy exposure. Investments in alternative and renewable energy are offered through both traditional equity investments as well as through alternative investment allocations among some client portfolios.

Additionally, we offer a training program to our team members within the wealth management division to educate them on responsible investing and how we can serve clients, most of which is by focusing on incorporating their values into their investment portfolios.

We also have a mechanism in place to receive and investigate any potential complaints related to responsible investing as part of our standard complaint program and to implement any necessary corrective action.

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 legal proceedings associated with fraud, insider trading, anti-trust, anti-competitive behavior, market manipulation, malpractice, or other related financial industry laws or regulations.