Statement in Relation to the Shareholder Rights Directive II


PIMCO Global Advisors (Luxembourg) S.A. (the “Company”) is authorised and regulated by the Commission de Surveillance du Secteur Financier (“CSSF”). The Company is required to comply with applicable Luxembourg rules transposing aspects of Article 3g of the Shareholder Rights Directive (SRD II) ((EU) 2017/828) (the “Article 3g Requirements”).

The Company is part of the PIMCO group (the “PIMCO Group”), one of the world’s premier fixed income investment advisors. As of 30 September 2020, the PIMCO Group had overall assets under management of US$2.02 trillion. As an investment advisor of primarily fixed income based products, investments in shares form only a small proportion of the PIMCO Group’s overall assets under management.

General Approach to Engagement

The PIMCO Group seeks to enrich and preserve client assets by providing high quality investment management services to its clients. The PIMCO Group’s engagement with issuers on behalf of its clients facilitates the responsible allocation and management of capital consistent with its clients’ investment objectives. Engagement activities may include, amongst other things, monitoring companies, assets and service providers, engaging companies and holding them to account on material issues and co-operating with other stakeholders. As an investment advisor of predominantly fixed income based products, the PIMCO Group typically engages with companies on behalf of clients that are bondholders.

Environmental, Social and Governance Matters

The PIMCO Group believes in investing in corporations that have demonstrated a sustainable framework for dealing with environmental, social and governance (“ESG”) matters. The PIMCO Group recognises that ESG-related issues are an increasingly critical factor in understanding global economies and has an ESG Investment Policy statement available at https://pim.co/y5eww and publishes an annual report on the PIMCO Group’s ESG activities. The most recent copy of the PIMCO Group’s ESG Investing Report is available at https://pim.co/acln8.

Shareholder Engagement

The Company delegates the portfolio management of all accounts, including those that hold shares, to other members of the PIMCO Group or third parties disclosed in the prospectus for the relevant fund. Consistent with its management responsibilities, the applicable investment advisor or sub-investment advisor will assume the authority for voting proxies and determine the level of the Company’s shareholder engagement. As a fiduciary, the Company will maintain oversight of the investment management responsibilities performed by the investment advisor. As a result, the Company has chosen at this stage not to implement an engagement policy pursuant to the Article 3g Requirements.

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This statement will be reviewed annually and, if applicable, updated to reflect changes in circumstances and practice.

October 2020