p.45

"We subscribe to multiple major global controversies research providers which provide alerts about incidents at public and private companies. Where portfolios have rules or restrictions against certain types or levels of severity of controversies, BlackRock's portfolio compliance team will code the newly restricted issuer into BlackRock's portfolio management and trading systems to ensure the mandate is prevented from purchasing the issuer, and in some cases divestment will be required. Where investors monitor ESG incidents investment terms preclude divestment or other investment action, as in cases where BlackRock is a limited partnerin a private equity fund, BlackRock’s investment team may require management explanation and remediation plans in addition to continued risk monitoring and reporting. In addition, and especially in the case of indexed strategies, whose investment objectives require committed investment in benchmark companies including after incidents occur, the BlackRock Investment Stewardship (BIS) team may engage with companies that have experienced a material controversy or incident to understand what happened, whether there was a management or board failure or weakness that contributed to the incident and what remedial actions have been taken to address the issue and minimize the likelihood it would reoccur. BIS may report such engagements in quarterly reports on our website."