Approach to sustainable investmentThe Manager has adopted a Sustainable Investment Philosophy. Thiswill initially be implemented for securities, but it is intended to beimplemented progressively over all asset classes over time as moresustainable investment options become available. This encompassesthree key elements:Sustainable investment exclusionsExclusions play a role in delivering part of our Sustainable InvestmentPhilosophy. For "AMP"-branded Funds, we use a mandate structure whichallows certain sectors and securities to be excluded.Integration of environmental, social and governance (ESG) considerationsinto our investment decisionsWhere possible, the Manager will implement a weighting to the “good”by overweighting our exposures to companies that have a higher ESGrating where we consider it appropriate to do so based on factors suchas expected returns, volatility and liquidity.We seek to achieve this overweighting by preferring indices (whereavailable and appropriate) that re-weight portfolios to companies thathave higher ESG ratings relative to others.Stewardship through voting and engagement with companiesAMP believes that stewardship is an important aspect of sustainableinvesting. The stewardship approach has two key aspects: (1) votingthrough shares held; and (2) engagement with companies. Stewardship activities will be undertaken by BlackRock exercising itsrights or engaging with companies on our behalf or in consultation withus. These activities focus on (1) board quality; (2) environmental risksand opportunities; (3) capital strategy and capital allocation; (4)compensation that promotes long-termism; and (5) human capitalmanagement.Monitoring and complianceWe monitor underlying investments on an ongoing basis to ensurecompliance with our Sustainable Investment Philosophy, includingensuring that BlackRock and custom index providers apply our exclusions.We also have processes in place to help identify any investment inexcluded securities and ensure that these are divested promptly.We use customized indices for some underlying funds, and regularlycheck that these indices are functioning as intended.Governance and reportingOur Sustainable Investment Philosophy is overseen by our InvestmentCommittee and regularly reviewed and updated. Our areas of focus willcontinue to evolve and change over time as we consider client andregulator feedback on sustainable investing issues.We will publish voting and engagement outcomes and make thesepublicly available on our website no less than six-monthly. In addition,we will provide regular updates on our areas of focus as part of regularcommunications to clients.Exclusion DescriptiontypeAll companies that provide components or services usedin the manufacturing of controversial weapons,including:Controversial weapons– Anti-Personnel Mines– Biological and Chemical Weapons– Cluster Weapons– Nuclear Weapons– Depleted Uranium– White PhosphorusCivilian firearmsAll producers of civilian firearms and any companiesthat earn more than 5% of their revenue from thedistribution, retail and supply of civilian firearms.Military weaponsAll companies deriving 5% or more revenue from theproduction of conventional weapons, weapons systems,components and support systems and servicesFossil fuelAll companies that earn revenues from the exploration,extraction, production, refinement, transportation andstorage of fossil fuels, including:– Arctic oil & gas– Oil & gas– Oil sands– Shale energy– Thermal coalNuclear powerAll companies generating (or that have installed capacityto generate) more than 5% of their electricity fromnuclear sourcesTobaccoAll producers of tobacco products and all companiesthat earn more than 5% of their revenue from thedistribution, retail and supply of tobacco-relatedproducts.Palm oilAll producers and any companies that earn revenue fromthe distribution and supply of palm oil.Whale productsCompanies that derive revenue from whale meatproduction.UN Global Compact violatorsAny companies that are assessed to be non-compliantwith the UN Global Compact principles.Primary industry exclusions Any companies with Primary Industry Exclusions asdefined by GICS codes2Integrated – Oil & Gas–Coal–Oil & Gas Drilling– Oil & Gas Equipment– Oil & Gas Exploration and Production– TobaccoNZ Super Fund exclusionsAny companies on the NZ Super Fund exclusion list.The exclusions criteria in the table above identify companies directlyinvolved with each of the areas noted, or if they are the majority owner(50% ownership or more) of other companies involved in any of thecriteria we are looking to exclude.An additional ‘significant ownership filter’ is used to identify and excludecompanies who own between 10% and 50% of any companies with anyinvolvement in one of the exclusions in the table above. In our approachwe only apply the significant ownership filter when we have totalexclusion of the activity, e.g. controversial weapons, fossil fuel, palm oil,etc.Integration of environmental, social and governance (ESG) considerationsinto our investment decisionsWhere possible, the Manager will implement a weighting to the “good”by overweighting our exposures to companies that have a higher ESGrating where we consider it appropriate to do so based on factors suchas expected returns, volatility and liquidity.We seek to achieve this overweighting by preferring indices (whereavailable and appropriate) that re-weight portfolios to companies thathave higher ESG ratings relative to others.Stewardship through voting and engagement with companiesAMP believes that stewardship is an important aspect of sustainableinvesting. The stewardship approach has two key aspects: (1) votingthrough shares held; and (2) engagement with companies.Stewardship activities will be undertaken by BlackRock exercising itsrights or engaging with companies on our behalf or in consultation withus. These activities focus on (1) board quality; (2) environmental risksand opportunities; (3) capital strategy and capital allocation; (4)compensation that promotes long-termism; and (5) human capitalmanagement.Monitoring and complianceWe monitor underlying investments on an ongoing basis to ensurecompliance with our Sustainable Investment Philosophy, includingensuring that BlackRock and custom index providers apply our exclusions.We also have processes in place to help identify any investment inexcluded securities and ensure that these are divested promptly.We use customised indices for some underlying funds, and regularlycheck that these indices are functioning as intended.Governance and reportingOur Sustainable Investment Philosophy is overseen by our InvestmentCommittee and regularly reviewed and updated. Our areas of focus willcontinue to evolve and change over time as we consider client andregulator feedback on sustainable investing issues.We will publish voting and engagement outcomes and make thesepublicly available on our website no less than six-monthly. In addition,we will provide regular updates on our areas of focus as part of regularcommunications to clients.More information on the Manager's approach to sustainable investmentis available at amp.co.nz/si.

The AMP KiwiSaver Conservative Fund follows the AMP Sustainable Investment Philosophy principles. The approach has three key elements: Sustainable Investment Exclusions; Integration of ESG considerations into our investment decisions; and Stewardship through voting and engagement with companies. Please see attached the threshold/ screening applied to the AMP Conservative Fund.  Thresholds for Screening_Q19response.docx 126.22 KB