Harbour uses quantitative screens in its investment process to rank investment opportunities. Harbour’s ESG score is included in all Harbour funds active quantitative screens. All other things being equal, a higher ESG score results in a better overall security ranking. Harbour is an active owner. Where conflicts arise with respect to company strategic direction, remuneration, or other material issues, Harbour will work with senior management, the Board ofDirectors, and other investors to find a satisfactory outcome for all stakeholders.

As part of our active ownership process Harbour recognizes there are many factors that influence our analysis, and that environmental, social and governance (ESG) considerations have grown in significance as potential value drivers. We believe that ESG factors can be a useful barometer of the quality of a company; Companies who manage ESG issues well are generally more likely to create long term shareholder value, with a reduced risk profile, compared with those companies who do not. Consequently, Harbour has integrated ESG factors directly into portfolio analysis. ESG factors are assessed in conjunction with existing comprehensive financial analysis. Our primary ESG tool is our proprietary Corporate Behaviour Survey, which we augment with external ESG specialists and broker research. Before consideration of companies in our integration approach, we have set a baseline standard of responsible behaviour based on business activity. Subsequently, the fund does not invest in companies that to our knowledge derive any revenue from: • The manufacture of tobacco • The manufacture or testing of nuclear explosive devices (NEDs) • The manufacture or sale of cluster munitions • The manufacture or sale of anti-personnel mines • The manufacture or sale of recreational cannabis• The production of pornography • The manufacture or sale of civilian automatic and semi-automatic firearms, magazines or parts