pg. 5

"(g) How We Engage with Companies on their Human Rights Impacts

BIS identifies companies for engagement based on our Engagement Prioritiesx our prior history of voting and engagement with the company, and our assessment of a company’s financial and governance performance relative to its peers. We also consider events that have impacted or may impact long-term shareholder value, including breaches of international standards that may result in adverse human rights impacts and create material business risks.

We may vote against directors if, in our assessment, a company is not effectively addressing or disclosing material human rights-related risks or impacts. Our assessment is based on information in the public domain, including third party research. In our direct dialogue with company leadership, we explore the topics outlined above, amongst others, to understand the company’s approach, provide feedback, and communicate our expectations.

We recognize that no single governance model or approach is universally appropriate for how companies address human rights issues, given variations in regional market practices. We leverage our regional presence and local expertise to inform our engagement on human rights, considering both international and local market standards, regulations, and context."

I changed the answer to No because the company refers to engagement as "We are committed to engaging with companies on how they manage the human rights issues that are inherent in their businesses and monitor human rights practices on a best-efforts basis" (p.4). Engagement seems to include voting against directors, etc. The company seems to refer throughout to their investment portfolio rather than screening prior to investment.