T. ROWE PRICE FUNDS SICAV US Blue Chip Equity Fund – ESG Report Providing transparency on Environment, Social and Governance aspects of the fund As at 30 June 2021 ESG INTEGRATION APPROACH • The US Blue Chip Equity Fund uses ESG integration as part of its investment process. This means incorporating environmental, social and governance factors to enhance investment decisions. Our philosophy is that ESG factors are a component of the investment decision – meaning that they are not the sole driver of an investment decision, nor are they considered separately from more traditional analysis. • The process of ESG integration takes place on two levels: first, with our research analysts as they incorporate environmental, social, and governance factors into company valuations and ratings; and, second, with the portfolio manager as he balances these ESG factor exposures at the portfolio level. Both the analysts and portfolio manager are able to leverage dedicated, in-house resources to assist them in analyzing ESG criteria. • Our ESG specialist teams provide investment research on ESG issues at the company level and on thematic topics. Additionally, they have built tools to help pro-actively and systematically analyze the environmental, social and governance factors that could impact our investments. The foundation of the analysis is a proprietary flagging tool called the Responsible Investing Indicator Model (RIIM). It covers approximately 15,000 securities and pulls from data sets that are not in the wheelhouse of traditional financial analysis. These data sets include: - ESG performance data (i.e. number of accidents, carbon emissions, strength of whistle-blower programs); - ESG targets (i.e. plans to reduce carbon emissions, increase diversity, etc.) - ESG incidents and controversies (i.e. environmental fines paid, local community controversies/protests against a company, etc.) • The portfolio is constructed on the basis of identifying high-quality large-cap growth companies that we believe can generate durable earnings and free cash flow growth that drive investment returns over time. As such, our primary emphasis is on company fundamentals, which include the consideration of environmental, social and governance factors. We also screen the portfolio using T. Rowe Price’s proprietary RIIM analysis at regular intervals. This helps us understand the ESG characteristics of the portfolio and makes us aware of any elevated exposures to specific ESG factors. This analysis is a valuable input to the portfolio construction process. RECENT COMPANY ENGAGEMENTS We maintain a regular dialogue with the management teams of companies represented across the portfolio. Our investment-driven engagement program frequently identifies targets through our proprietary RIIM analysis, governance screening and analysts’ fundamental research. While we engage with companies in a variety of different contexts, ESG engagement focuses on learning about, influencing or exchanging perspectives on the environmental practices, corporate governance or social issues affecting their business. While most of the meetings we hold with company managements will include some discussion of ESG topics, we differentiate meetings held with a heavy focus on ESG, meaning ESG issues were the sole items on the agenda or made up a meaningful part of the meeting. Agenda items are classified as “meaningful” when they take up a significant portion of the meeting or are a significant factor in the investment case. The following are selected examples of recent engagements with companies held in or considered for the portfolio. The examples are not meant to be representative of every engagement held, but to illustrate the types of ESG engagements we are having with the managements of our investment companies. For Investment Professionals only. Not for further distribution T. Rowe Price Funds SICAV US Blue Chip Equity Fund As at 30 June 2021 Alibaba (1st Quarter 2021) Focus Environment, Social Company Description Alibaba operates the dominant e-commerce platform in China. We engaged with Alibaba to request better ESG disclosure and to discuss Engagement Objective a range of ESG issues. From Alibaba: Investor Relations Participants From T. Rowe Price: Impact Portfolio Manager, Portfolio Manager (Equity), Responsible Investing Analyst The purpose of our engagement with Alibaba was to request better ESG disclosure and to hold a discussion on its emissions and environment footprint, antitrust and supplier treatment, and employee well-being. Regarding disclosure, we had not observed any improvement in Alibaba’s ESG disclosure, data measurement, or preparedness (e.g., targets or programs) since its 2018 report and raised that as an issue. On the environmental front, we focused on the impacts of Alibaba’s shipments and cloud business. We shared our view that Alibaba has a large opportunity to reduce the emissions associated with parcel delivery in China, e.g., by working with logistics partners or setting environmental targets. Alibaba said that its data centers adhere to “green best practices,” Engagement Outcome but the lack of emissions or renewable energy data makes it difficult to give the company credit for this claim. Our social discussion focused on labor welfare, supplier treatment, and data privacy. For example, we discussed how Alibaba monitors mental health risks given the long hours of China’s tech industry culture. Alibaba’s view was that the media has exaggerated the issue and highlighted several ways in which it surveys worker sentiment. The engagement allowed us to highlight the importance of environmental management and to request that Alibaba to improve its ESG data disclosure. We will continue to monitor the development of antitrust regulation, particularly in the context of supplier terms. The specific securities identified and described do not represent all of the securities purchased, sold, or recommended for the SICAV sub-fund, and no assumption should be made that the securities identified and discussed were or will be profitable. T. Rowe Price may have ongoing business and/or client relationships with the companies mentioned in this report. T. Rowe Price Funds SICAV US Blue Chip Equity Fund As at 30 June 2021 Snap (1st Quarter 2021) Focus Environment, Social Company Description Snap is the social media company behind the mobile app Snapchat. We engaged with Snap to discuss the company’s approach to Engagement Objective sustainability reporting and the issue of data privacy around Snap Messaging and Spectacles. From Snap: Strategic Finance and Investor Relations, Finance Participants From T. Rowe Price: Equity Research Analyst; Director of Research, Responsible Investing; Responsible Investing Analyst The purpose of our engagement with Snap Inc. was to encourage better ESG disclosure and to discuss the company’s data practices, particularly regarding privacy disclosure. Snap has average ratings from Sustainalytics and MSCI due to its historically limited disclosure. We recommended that the company 1) report ESG metrics alongside financial reporting to show how ESG issues are embedded into management decision-making, 2) use Sustainability Accounting Standards Board and Task Force on Climate-Related Financial Disclosures frameworks for reporting, and 3) report on diversity and carbon emissions (including material scope 3 emissions). On the data privacy front, we focused on the Snapchat app and Spectacles, areas where privacy disclosure is opaque. Snapchat has Engagement Outcome historically mischaracterized the “disappearing” nature of the content that users share, and as of 2020, Snap’s privacy policy stated that users should not send content they wouldn’t want saved. Our primary concern was whether snap messages were still retrievable from a recipients device with the product’s current design. We also asked the company to elaborate on their privacy policies for the Spectacles product. Snap advised that once Snaps are deleted (and they are designed to delete by default once opened or expired), they are not stored or cached on a user's device. Regarding Spectacles, there are ethical concerns related to smart glasses, including location tracking data and the potential for people to be recorded without their knowledge. Snap informed us that they do not collect any facial or voice data. They also provide users an option to download a copy of their data Snap stores (location, device, metadata, and others). T. Rowe Price Funds SICAV US Blue Chip Equity Fund As at 30 June 2021 Snap (1st Quarter 2021) The engagement allowed us to impart our views on best practices around ESG issues and encourage improved disclosure. Two months after our engagement, Snap sent their 2021 Citizen Snap Report, the most comprehensive report to date. The Citizen Snap report discloses: • A materiality matrix of issues Snap Inc. prioritizes Engagement Outcome • Company ESG data reported within Sustainability Accounting (continued) Standards Board and Global Reporting Initiative frameworks • Diversity representation statistics broken down by race/ethnicity (US) and gender (global) • Scopes 1, 2, and 3 emissions and outlines science-based emission reduction targets • The company’s approach to using ethics-, privacy-, safety-, and inclusion-by-design as foundational principles in their products 1 Scope 1 (direct emissions from owned or controlled sources); Scope 2 (indirect emissions from the generation of purchased electricity, steam, or cooling); Scope 3 (all other indirect emissions). The specific
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