Report - COP Prototype

2022 Communication on Progress

T. Rowe Price Group, Inc.

Published date

June 1, 2022

No. of questions

Supplemental files

COE March 7 2022_FINAL.pdf human-rights-violators-policy.pdf T Rowe Price_FY2021_Cventure Verification Statement_FINAL_May 4 2022.pdf T Rowe Price_FY2021_Cventure Verification Statement_FINAL_May 4 2022.pdf Modern_Slavery_and_Human_Trafficking_Statement.pdf COE March 7 2022_FINAL.pdf

CEO Statement

Signed

Governance

Policies and Responsibilities

1. Does the Board / highest governance body or most senior executive of the company:

Issue an annual statement about the relevance of sustainable development to the company

Issue an annual statement that addresses impacts on both people and the environment

Issue an annual statement highlighting a zero tolerance for corruption

Sign off on organizational sustainability targets

Supervise Environmental, Social, and Governance reporting

Regularly review potential risks related to the business model

None of the above

2. Does the company have a publicly stated commitment regarding the following sustainability topics?

	No, this is not a current priority	No, but we plan to have a commitment within 2 years	Yes, and the commitment is focused on our own operations	Yes, and the commitment includes our own operations and the value chain	Yes, and the commitment includes our own operations and the value chain along with communities and society
Human Rights
Labour Rights / Decent Work
Environment
Anti-Corruption

Optional comment

Please see the Human Resources section of our Code of Ethics (https://www.troweprice.com/content/dam/trowecorp/Pdfs/COE%20March%207%202022_FINAL.pdf), which details our commitments to equal opportunity and a safe working environment for all employees, and our Human Rights Violators Exclusion Policy (https://www.troweprice.com/content/dam/ide/articles/collections/esg/human-rights-violators-policy.pdf), which details our policy not to finance companies involved in genocide and/or crimes against humanity.

3. Does the company have in place a code of conduct regarding each of the following sustainability topics?

	No, this is not a current priority	No, but we plan to have a code of conduct within two years	Yes, focused on employee conduct	Yes, focused on employees and suppliers	Yes, focused on employees, suppliers, and other business relationships
Human Rights
Labour Rights / Decent Work
Environment
Anti-Corruption

4. Has the company appointed an individual or group responsible for each of the following sustainability topics?

	No one is specifically responsible for this topic	Yes, with limited influence on outcomes (e.g., limited access to internal information, limited decision-making authority)	Yes, with moderate influence on outcomes (e.g., has access to relevant information, reports to senior manager)	Yes, with direct influence of some outcomes (e.g., has access to relevant information, includes one or more senior manager with decision making rights	Yes, with direct influence at the highest levels of the organization (e.g., has access to relevant information, includes most senior members of organization)
Human Rights
Labour Rights / Decent Work
Environment
Anti-Corruption

5. Does the company have a formal structure(s) (such as a cross-functional committee) to address each of the following sustainability topics?

	No formal structure	Yes, and with limited influence on outcomes (e.g., limited access to internal information necessary to understand risks, poor representation from relevant departments or functions)	Yes, with moderate influence on outcomes (e.g., it includes representatives of some functions, departments, or business units most relevant for addressing the risks concerned, has access to relevant information, reports to senior manager)	Yes, with direct influence on some outcomes (e.g., it includes representatives of functions, departments, or business units most relevant for addressing the risks concerned, has access to relevant information, it involves one or more members of senior management)	Yes, and with direct influence at the highest level of the organization (e.g., full access to relevant information, it involves members at highest level of organization)
Human Rights
Labour Rights / Decent Work
Environment
Anti-Corruption

Prevention

6. Does the company have a process or processes to assess risk?

	No, this is not a current priority	No, but we are planning to develop one in the next two years	Yes, related to our own operations	Yes, related to our own operations and entire value chain and other business relationships
Human rights risks
Labour rights risks
Environmental risks
Corruption risks

6.1. During the assessment of risk, which business relationships are reviewed?

	A few suppliers or business relationships [approximately less than 25 %]	Several suppliers / business relationships (i.e., first tier or other high priority) [approx. 25 - 50 %]	Most suppliers / relevant business relationships [approx. 51 - 99 %]	All suppliers / relevant business relationships outside the supply chain
Human rights risks
Labour rights risks
Environmental risks
Corruption risks

7. Does the company have a due diligence process through which it identifies, prevents, mitigates, and accounts for actual and potential negative impacts on sustainability topics?

	No, this is not a current priority	No, but we are planning to develop one in the next two years	Yes, related to our own operations	Yes, related to our own operations and entire value chain and other business relationships
Human rights risks
Labour rights risks
Environmental risks
Corruption risks

7.1. During the due diligence process, which business relationships are reviewed?

	A few suppliers or business relationships [approximately less than 25 %]	Several suppliers / business relationships (i.e., first tier or other high priority) [approx. 25 - 50 %]	Most suppliers / relevant business relationships [approx. 51 - 99 %]	All suppliers / relevant business relationships outside the supply chain
Human rights risks
Labour rights risks
Environmental risks
Corruption risks

Optional comment

Our Supplier Management Program includes a corporate risk assessment conducted by our Supplier Management team. For key suppliers, this assessment includes review of the supplier’s reputation, company principals, legal and compliance program, country program, human resources program, and risk management program.

Concerns and grievance mechanisms

8. Are there any processes through which members of the company’s workforce can raise concerns about the company’s conduct related to human rights, labour rights, environment, or anti-corruption?

No, this is not a current priority

No, but we plan to within two years

Yes, we have an informal process (e.g., through supervisors, others)

Yes, we have a formal process

8.1. Please provide additional detail regarding the process(es) the company has through which members of the company’s workforce can raise concerns about the company’s conduct.

	No	Yes
Is the process communicated to all employees/workers in local languages?
Is the process available to non-employees (e.g., contractors, vendors, suppliers)?
Is the process confidential (e.g., whistleblowing process)?
Are there processes in place to avoid retaliation?
Can concerns be raised about suppliers or other business relationships (e.g., clients, partners, etc.)
Other (Please provide additional information)

9. Does the company provide or enable access to effective remedy to right holders / stakeholders where it has caused or contributed to the adverse impact?

	No process to enable remedy to stakeholders	Remedy available to some stakeholders (i.e., some geographies, employees only)	Remedy is available to all affected stakeholders	Remedy is available to all stakeholders, and suppliers are expected to have similar policies
Human Rights
Labour Rights / Decent Work
Environment
Anti-Corruption

Optional comment

The Human Resources section of our Code of Ethics, along with our Associate Handbook, offer remedy for labour rights, human rights, and anti-corruption. Additionally, our whistleblower policies and procedures allow any employee to anonymously report suspected corruption.

Lessons

10. How does the company capture lessons regarding each of the following sustainability topics?

	No lessons are regularly captured	Conducts root cause analyses/investigation of major incidents	Conducts root cause analyses/investigation and changes organizational policies, processes, and practices accordingly	Systematically conducts root cause analyses/investigation and leverages learnings to influence both internal and external affairs
Human Rights
Labour Rights / Decent Work
Environment
Anti-Corruption

Executive Pay

11. Is executive pay linked to performance on one or more of the following sustainability topics?

Board Composition

12. Percentage of individuals within the company’s Board / highest governance body by:

	Number/Percentage	Not applicable (Please provide additional information)
Total number of board members (#)	14
Male (%)	64
Female (%)	36
Non-binary (%)	0
Under 30 years old (%)	0
30-50 years old (%)	7
Above 50 years old (%)	93
From minority or vulnerable groups (%)	29
Executive (%)	21
Independent (%)	79

Data Assurance

14. Is the information disclosed in this questionnaire assured by a third-party?

No assurance for any metrics

Limited assurance for minority of metrics (e.g., GHG emissions only)

Limited assurance for majority of metrics

Reasonable assurance for minority of metrics

Cventure LLC verifies T. Rowe Price's greenhouse gas emissions.

Reasonable assurance for majority of metrics

Other (Please provide additional information)

Human Rights

Commitment

2. Does the company have a policy commitment in relation to the following human rights issues?

	No, and we have no plans to develop a policy	No, but we plan to in the next two years	Yes, included within a broader policy	Yes, articulated as a stand-alone policy
Rights of women and/or girls
2022
Freedom of expression
Rights of refugees and migrants
Digital security / privacy
2021
Rights of indigenous peoples
Access to culture
Free, prior and informed consent
Access to water and sanitation

2.1. For each human rights policy, is it:

	Aligned with international human rights standards?	Publicly available?	Approved at most senior level of the company?	Applied to the company’s own operations?	Applied to the company’s supply chain and/or other business relationships?	Developed involving human rights expertise from inside and outside the company?	Other (Please provide additional information)
Freedom of expression
Digital security / privacy
Rights of women and/or girls
Access to culture
Rights of indigenous peoples
Free, prior and informed consent
Rights of refugees and migrants
Access to water and sanitation

Prevention

3. In the course of the reporting period, has the company engaged with affected stakeholders or their legitimate representatives in relation to the following human rights issues?

	No engagement on this topic	To better understand the risks/ impacts in question	To discuss potential ways to prevent or mitigate the risks/ impacts in question	To agree on a way to prevent/ mitigate the risks/ impacts in question	To assess progress in preventing /mitigating the risks/impacts in question	To collaborate in the prevention/ mitigation of the risks/ impacts in question
Rights of women and/or girls
Freedom of expression
Rights of refugees and migrants
Digital security / privacy
Rights of indigenous peoples
Access to culture
Free, prior and informed consent
Access to water and sanitation

4. What type of action has the company taken in the reporting period with the aim of preventing/mitigating the risks/impacts associated with this human rights issue?

	Provided internal training/ capacity building for the direct workforce	Building capacity among relevant business relationships (e.g., partners, suppliers, clients, etc.)	Conducting an audit process and/or corrective action plan	Collective Action with peers or other stakeholders to address the issue	Collaboration with governmental or regulatory bodies	Other (Please provide additional information)	No action within reporting period
Rights of women and/or girls
Freedom of expression
Rights of refugees and migrants
Digital security / privacy
Rights of indigenous peoples
Access to culture
Free, prior and informed consent
Access to water and sanitation

5. Who receives training for the following human rights issues?

	No training provided	Select employees	All employees	Contractors	Direct suppliers of the organization	Indirect suppliers of the organization	Other – such as partners, clients, etc.
Rights of women and/or girls
Freedom of expression
Rights of refugees and migrants
Digital security / privacy
Rights of indigenous peoples
Access to culture
Free, prior and informed consent
Access to water and sanitation

6. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following human rights issues?

	No monitoring of progress	Review issues on ad-hoc basis	Set annual targets/ goals, track progress over time (internal programs only)	Set annual targets/ goals, track progress over time (internal and external programs)	Other (Please provide additional information)
Rights of women and/or girls
Freedom of expression
Rights of refugees and migrants
Digital security / privacy
Rights of indigenous peoples
Access to culture
Free, prior and informed consent
Access to water and sanitation

Response

7. During the reporting period, has the company been involved in providing or enabling remedy where it has caused or contributed to adverse impact associated with the following human rights issue(s)?

	Yes	No	Choose to not disclose	Not applicable (Please provide additional information)
Rights of women and/or girls
No reportable adverse impact.
Freedom of expression
Rights of refugees and migrants
Digital security / privacy
No reportable adverse impact.
Rights of indigenous peoples
Access to culture
Free, prior and informed consent
Access to water and sanitation

8. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the human rights principles, including any challenges faced and actions taken towards prevention and/or remediation.

T. Rowe Price has adopted a policy to refrain from investing in certain securities that, in our estimation, pose high risk due to their exposure to supporting governments carrying out genocide and/or crimes against humanity. The policy targets companies that exhibit a blatant disregard for due diligence on genocide and/or crimes against humanity and have repeatedly been involved in supporting governments carrying out these events. The full policy can be viewed online: https://www.troweprice.com/content/dam/ide/articles/collections/esg/human-rights-violators-policy.pdf

Labour

Commitment

1. Does the company have a policy commitment in relation to the following labour rights principles?

	No, and we have no plans to develop a policy	No, but we plan to in the next two years	Yes, included within a broader policy	Yes, articulated as a stand-alone policy	Not applicable (Please provide additional information)
Freedom of association and the effective recognition of the right to collective bargaining
Forced labour
2021
Child labour
Non-discrimination in respect of employment and occupation
2022
Occupational safety and health
2022
Working conditions (wages, working hours)
2022

Optional comment

Non-discriminational and Occupational Safety and Health policies are covered within our Code of Ethics (https://www.troweprice.com/content/dam/trowecorp/Pdfs/COE%20March%207%202022_FINAL.pdf). Working conditions are covered in our Associate Handbook. T. Rowe Price International, a wholly owned subsidiary of T. Rowe Price Group, has an Modern Slavery and Human Trafficking Statement (https://www.troweprice.com/content/dam/ide/footer/Modern_Slavery_and_Human_Trafficking_Statement.pdf) which discusses the firm's policies on forced labour.

1.1. For each labour rights policy, is it:

	Aligned with international labour standards?	Publicly available?	Approved at most senior level of the company?	Applied to the company’s own operations?	Applied to the company’s supply chain and/or other business relationships?	Developed involving labour rights expertise from inside and outside the company?	Other (Please provide additional information)
Freedom of association and the effective recognition of the right to collective bargaining
Forced labour
Child labour
Non-discrimination in respect of employment and occupation
Occupational safety and health
Working conditions (wages, working hours)

Optional comment

Regarding Forced Labour, T. Rowe Price International, which is a wholly owned subsidiary of T. Rowe Price Group, has an Modern Slavery and Human Trafficking Statement (https://www.troweprice.com/content/dam/ide/footer/Modern_Slavery_and_Human_Trafficking_Statement.pdf), which discusses policies applicable to suppliers.

Prevention

2. In the course of the reporting period, has the company engaged with affected stakeholders or their legitimate representatives in relation to the following labour rights issues?

	No engagement on this topic	To better understand the risks/ impacts in question	To discuss potential ways to prevent or mitigate the risks/ impacts in question	To agree on a way to prevent/ mitigate the risks/ impacts in question	To assess progress in preventing/ mitigating the risks /impacts in question	To collaborate in the prevention/ mitigation of the risks/ impacts in question	Other (Please provide additional information)
Freedom of association and the effective recognition of the right to collective bargaining
Forced labour
Child labour
Non-discrimination in respect of employment and occupation
Occupational safety and health
Throughout the COVID-19 Pandemic, we leveraged guidance from global health officials and other medical experts in connection with developing our remote working, return to office, masking, and vaccination strategy in order to promote a heathy and safe working environment for our associates.
Working conditions (wages, working hours)
Throughout the COVID-19 Pandemic, we leveraged guidance from global health officials and other medical experts in connection with developing our remote working, return to office, masking, and vaccination strategy in order to promote a heathy and safe working environment for our associates.

3. What type of action has the company taken in the reporting period with the aim of preventing/mitigating the risks/impacts associated with this labour rights issue?

	Provided internal training/ capacity building for the direct workforce	Building capacity among relevant business relationships (e.g., partners, suppliers, clients, etc.)	Conducting an audit process and/or corrective action plan	Collective Action with peers or other stakeholders, in particular workers' organizations, to address the issue	Collaboration with governmental or regulatory bodies	Other (Please provide additional information)	No action within reporting period
Freedom of association and the effective recognition of the right to collective bargaining
Forced labour
Child labour
Non-discrimination in respect of employment and occupation
Occupational safety and health
Throughout the COVID-19 Pandemic, we leveraged guidance from global health officials and other medical experts in connection with developing its remote working, return to office, masking, and vaccination strategy in order to promote a heathy and safe working environment for our associates.
Working conditions (wages, working hours)
Throughout the COVID-19 Pandemic, we leveraged guidance from global health officials and other medical experts in connection with developing our remote working, return to office, masking, and vaccination strategy in order to promote a heathy and safe working environment for our associates.

4. Who receives training for the following labour rights issues?

	No training provided	Select employees	All employees	Contractors	Direct suppliers of the organization	Indirect suppliers of the organization	Other – such as partners, clients, etc.
Freedom of association and the effective recognition of the right to collective bargaining
Forced labour
Child labour
Non-discrimination in respect of employment and occupation
Occupational safety and health
Working conditions (wages, working hours)

5. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following labour rights issues?

	No monitoring of progress	Review issues on ad-hoc basis	Set annual targets/ goals, track progress over time (internal programs only)	Set annual targets/ goals, track progress over time (internal and external programs)	Other (Please provide additional information)
Freedom of association and the effective recognition of the right to collective bargaining
Forced labour
T. Rowe Price International, a wholly owned subsidiary of T. Rowe Price Group, has a Modern Slavery and Human Trafficking Statement. (https://www.troweprice.com/content/dam/ide/footer/Modern_Slavery_and_Human_Trafficking_Statement.pdf).
Child labour
T. Rowe Price International, a wholly owned subsidiary of T. Rowe Price Group, has a Modern Slavery and Human Trafficking Statement. (https://www.troweprice.com/content/dam/ide/footer/Modern_Slavery_and_Human_Trafficking_Statement.pdf).
Non-discrimination in respect of employment and occupation
Occupational safety and health
We have a Health & Safety team in place to monitor legal requirements and action any requirements/changes.
Working conditions (wages, working hours)
Our compensation team analyzes market data and ensures wages remain fair and in line with legislation and industry practices, as well as an Employment Law team to ensure we keep abreast of any changes in legislation as they relate to working hours.

Performance

6. What is the percentage of employees covered under collective bargaining agreements?

	Percent of employees (%)	Unknown
Employees covered under collective bargaining (%)	0

7. What is the percentage of employees in a trade union or other workers' organization?

	Percent of employees (%)	Unknown	Not applicable (Please provide additional information)
Employees in a trade union or on a worker committee (%)	0

Optional comment

Within our global workforce of 7500 employees, in compliance with local laws relating to staff representation, two elected staff delegates in Luxembourg and one elected employee representative in Japan represent workers in their respective local markets.

8. In the course of the reporting period, what was the percentage of women in:

	Percent of women (%)	Unknown
Senior leadership level position	39
Non-executive board	45

Optional comment

Senior leadership level data is reflective of U.S. workforce only and based on U.S. EEO classification of "Executive/Senior Level Officials and Managers."

9. What was the average ratio of the basic salary and remuneration of women to men (comparing jobs of equal value) during the reporting period?

	Salary ratio (%)	Unknown	Choose to not disclose
Women / Men (%)
While we regularly assess pay equity and equal pay for equal work, and take actions where appropriate, we do not calculate nor report that specific metric globally.

10. In the course of the reporting period, how frequently were workers injured (injuries per hour worked)?

	Frequency of injury	Unknown	Choose to not disclose
Frequency of injury

11. In the course of the reporting period, what was the company’s incident rate?

	Incident rate	Unknown	Choose to not disclose
Incident rate

Response and Reporting

12. In the course of the reporting period, has the company been involved in providing or enabling remedy where it has caused or contributed to the adverse impact associated with the following labour rights issues?

	Yes	No	Choose to not disclose	Not applicable (Please provide additional information)
Freedom of association and the effective recognition of the right to collective bargaining
Forced labour
Child labour
Non-discrimination in respect of employment and occupation
Occupational safety and health
Working conditions (wages, working hours)

13. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the labour rights principles, including any challenges faced and actions taken towards prevention and/or remediation.

With regard to our own workforce, there are no actions to report. As an investment manager, we consider labour or human capital issues to be material in our investment analysis and often engage with companies on this topic. In 2021, 21% of our 788 engagements with companies were on social issues, with the top three categories were disclosure of social data; employee safety and treatment; and diversity, equity, and inclusion.

Environment

Commitment

1. Does the company have a formal policy on the following environmental topics?

	No, and we have no plans to develop a policy	No, but we plan to in the next two years	Yes, included within a broader policy	Yes, articulated as a stand-alone policy	Not applicable (Please provide additional information)
Climate Action
2016
Water
2016
Oceans
Forests / Biodiversity / Land Use
Air Pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
2016
Energy & Resource Use
2016

Optional comment

Environmental policy is available online at https://www.troweprice.com/content/dam/trowecorp/Pdfs/Environmental%20Policy.pdf.

1.1. For each environmental policy, is it:

	Aligned with international environmental standards?	Publicly available?	Approved at most senior level of the company?	Applied to the company’s own operations?	Applied to the company’s supply chain and/or other business relationships?	Developed involving environmental expertise from inside and outside the company?	Other (Please provide additional information)
Climate Action
Water
Oceans
Forests / Biodiversity / Land Use
Air Pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Energy & Resource Use

Prevention

2. In the course of the reporting period, has the company engaged with affected stakeholders or their legitimate representatives in relation to the following environmental issues?

	No engagement on this topic	To better understand the risks/ impacts in question	To discuss potential ways to prevent or mitigate the risks/ impacts in question	To agree on a way to prevent/ mitigate the risks/ impacts in question	To assess progress in preventing/ mitigating the risks/ impacts in question	To collaborate in the prevention/ mitigation of the risks/ impacts in question	Other (Please provide additional information)
Climate Action
Water
Oceans
Forests / Biodiversity / Land Use
Air Pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Energy & Resource Use

Optional comment

With regard to our operations, while we have not had stakeholders who experienced environmental impacts from our facilities, we are in the process of moving our global headquarters in Baltimore, Maryland, as well as our London office. We have engaged community members, suppliers, nonprofits, and elected officials to understand the environmental impact of our facilities and develop strategies for reducing it. In Baltimore, our new headquarters will be on the waterfront of the Patapsco River, a tributary feeding the Chesapeake Bay. To support the health of the Chesapeake Bay, our headquarters will feature a water harvesting system that will save approximately 1.55 million gallons of water annually. Using rainwater in the flush fixtures of the building will enable us to reduce potable water usage by 50%. We will also cultivate oyster gardens at our headquarters, not only to support the biodiversity of the Chesapeake Bay, but also to help improve water quality, as a fully grown oyster can filter harmful pollutants out of up to 50 gallons of water per day. Additionally, in response to a shareholder proposal from Zevin Asset Management, requesting that our board initiate a review and issue a report on the proxy voting policies related to climate change, we engaged with them to better understand their concerns and share our plans to enhance disclosures related to proxy voting. We believed no benefit would be realized from the implementation of their proposal, and our recommendation that shareholders vote against it was overwhelmingly supported.

3. What type of action has the company taken in the reporting period with the aim of preventing/mitigating the risks/impacts associated with these environmental topics?

	Provided internal training/ capacity building for the direct workforce	Building capacity among relevant business relationships (e.g., partners, suppliers, clients, etc.)	Conducting an audit process and/or corrective action plan	Collective Action with peers or other stakeholders to address the issue	Collaboration with governmental or regulatory bodies	Other (Please provide additional information)	No action within reporting period
Climate Action
Water
Oceans
Forests / Biodiversity / Land Use
Air Pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Energy & Resource Use

4. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following environmental topics?

	No monitoring of progress	Review issues on ad-hoc basis	Set annual targets/ goals, track progress over time (internal programs only)	Set annual targets/ goals, track progress over time (internal and external programs)	Other (Please provide additional information)
Climate Action
Water
Oceans
Forests / Biodiversity / Land Use
Air Pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Energy & Resource Use

4.1. For each environmental topic in which the company sets timebound goals / targets, what kind of targets has the company set?

	Description of targets (e.g., what is the target, absolute vs. intensity, externally verified, on track, etc.)
Climate Action	T. Rowe Price has set the target of reducing our greenhouse gas emissions by 13% by 2025, compared with a 2010 baseline. We continue to be on track to meet this target in advance of the 2025 deadline and, therefore, we aim to build on this progress by exploring what new, future-proof carbon and energy targets would be most appropriate for our business.
Energy & Resource Use	T. Rowe Price has set the target of reducing our greenhouse gas emissions by 13% by 2025, compared with a 2010 baseline. We continue to be on track to meet this target in advance of the 2025 deadline and, therefore, we aim to build on this progress by exploring what new, future-proof carbon and energy targets would be most appropriate for our business.
Water
Forests / Biodiversity / Land Use
Air Pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)	T. Rowe Price has set a target of reducing the waste we send to landfill by 92% by 2025, compared with a 2010 baseline. We remain on track to meet this target in advance of the 2025 deadline. We are committed to building on this momentum, and as such, we will explore the possibilities for reducing our significant sources of waste by seeking out circular economy options.
Oceans

4.2. For each environmental topic in which the company sets timebound goals / targets, how is progress against target / goal tracked?

	Progress is reviewed against goals annually or more frequently	Progress is reported internally to the most senior level	Progress is reported externally	Other (Please provide additional information)
Climate Action
Energy & Resource Use
Water
Forests / Biodiversity / Land Use
Air Pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Oceans

5. In the course of the reporting period, has the company been involved in providing or enabling remedy for any actual impacts associated with the following environmental issue(s)?

	Yes	No	Choose to not disclose	Not applicable (Please provide additional information)
Climate Action
Water
Oceans
Forests / Biodiversity / Land Use
Air Pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Energy & Resource Use

Climate Action

6. What were the company’s gross global greenhouse gas emissions for the reporting period?

Scope 1 Emissions

Full

None

Emissions (tCO2e)

Scope 2 Emissions

Full

None

Emissions (tCO2e)

Scope 3 Emissions

Full

Partial

None

Emissions (tCO2e)

Optional comment

Scope 1: 877 CO2 MT; Scope 2: 18,887 CO2 MT; Scope 3: 468 CO2 MT

7. What percentage of the company's revenue was invested in R&D of low-carbon products/services during this reporting period?

Percent of revenue (%)

Unknown

Not applicable (Please provide additional information)

8. Has the organization acted to support climate change adaptation and resilience?

We have taken action to increase organization-wide resilience to climate change

We have taken action to increase resilience in our supply chains

We have taken action to increase resilience in the communities in which we operate

We have provided funding for climate change adaptation and resilience initiatives and projects

We have not taken actions to build climate change resilience in the reporting period

Other (Please provide additional information)

Unknown

Energy / Resource Use

9. Please report the company's renewable energy consumption as a percentage of total energy consumption in the reporting period.

% of total energy consumption

Unknown

Technology

10. What percent of the company's revenue came from environmentally friendly products / services during this reporting period?

Percent of total revenue (%)

Unknown

Not applicable (Please provide additional information)

Optional comment

We manage ESG investing strategies on behalf of our clients, but do not have a specific investing strategy that addresses exclusively environmental impacts.

Overall Environment

21. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the environment principles, including any challenges faced and actions taken towards prevention and/or remediation.

T. Rowe Price has joined the Net Zero Asset Managers initiative to support the goal of net zero greenhouse gas emissions by 2050 or sooner, in line with global efforts to limit warming to 1.5 degrees Celsius. We continue to advocate to our investee companies that they utilize the Task Force on Climate-Related Financial Disclosures framework to disclose material information related climate risks. With regard to our own operations, we have set targets to manage climate-related risks and opportunities for two areas: greenhouse gas emissions and waste. For greenhouse gas emissions, we have set the target of reducing our emissions by 13% by 2025, compared with a 2010 baseline. We continue to be on track to meet this target in advance of the 2025 deadline and, therefore, we aim to build on this progress by exploring what new, future-proof carbon and energy targets would be most appropriate for our business. For waste, we have set a target of reducing the waste we send to landfill by 92% by 2025, compared with a 2010 baseline. As with greenhouse gas emissions, we remain on track to meet this target in advance of the 2025 deadline. We are committed to building on this momentum, and as such, we will explore the possibilities for reducing our significant sources of waste by seeking out circular economy options, which can be used to tackle both our operational and embodied waste. Additionally, as construction on our new global headquarters begins, we are working towards the goal LEED Platinum status for commercial interiors.

Anti-corruption

Commitment

1. Does the company have an anti-corruption compliance programme?

No, it is not an immediate business priority

No, but we plan to in the next two years

Yes

2021

2. Does your company have policies and recommendations for employees on how to act in case of doubt and/or in situations that may represent a conflict of interest, e.g. with regard to gifts and hospitality, donations, sponsorship, or interactions with public officials?

No, and we have no plans to develop a policy

No, but we plan to in the next two years

Yes, included within a broader policy

Yes, articulated as a stand-alone policy

Prevention

3. Who receives training on anti-corruption and integrity?

3.1. How often is such training provided?

	One time only	Every year	Every two or more years	We do not collect this data
All employees
Select employees
Contractors
Direct suppliers of the organization
Other – such as partners, clients, etc.
Indirect suppliers of the organization

4. Does the company monitor its anti-corruption compliance programme?

No, we do not monitor the anti-corruption compliance programme

Review issues on ad-hoc basis

Yes, through internal employee self-evaluations

Yes, through automated controls monitoring

Yes, through external independent monitoring

Yes, through other mechanisms

Internal Audit engaged outside consultants during the reporting period to review our anti-corruption program.

Response and Reporting

5. Please report the company's total number and nature of incidents of corruption during the reporting year.

	Number of incident(s)	Unknown	Choose to not disclose
Confirmed during the current year, but related to previous years	0
Zero incidents
Confirmed during the current year, and related to this year	0
Zero incidents

6. Within the reporting period, what measures has the company taken to address suspected incidents of corruption independently or in response to a dispute or investigation by a government regulator?

Initial case assessment

Internal investigation

Review by risk / ethics committee

Review by board of directors

External audit / review

Other (please provide additional information)

Not applicable/no incidents in the reporting period

7. Does your company engage in Collective Action against corruption?

No, it is not an immediate business priority

No, but we plan to in the next two years

Yes (please explain)

8. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the anti-corruption principle, including any challenges faced and actions taken towards prevention and/or remediation.

T. Rowe Price reviews its global anti-corruption policy annually and trains associate annually on how to prevent, identify, and report potential corruption issues. During the reporting period, we enhanced our automated and manual anti-corruption monitoring processes.