Report - COP Prototype

2022 Communication on Progress

Schroders PLC

Published date

June 28, 2022

No. of questions

Supplemental files

Schroders 2021 GHG Data Assurance Statement_v0.2.pdf Annual_Report_and_Accounts_2021.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

Optional comment

Please see the Group Chief Executive's Statement in our Annual Report and Accounts (https://prod.schroders.com/en/sysglobalassets/annual-report/2021/documents/Annual_Report_and_Accounts_2021.pdf). The sign-off on organisational sustainability targets is delegated to the Group Chief Executive from the Schroders plc Board.

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

- Our Group Human Rights Statement: https://www.schroders.com/en/sysglobalassets/about-us/group-human-rights-statement-v1_2021_external.pdf - Group Climate Change Position Statement: https://www.schroders.com/en/sysglobalassets/about-us/new/planet/group-climate-change-position-statement-2022_ext-26.05.22.pdf - Inclusion and Diversity website: https://www.schroders.com/en/about-us/people-and-culture/inclusion/ - Supplier Code of Conduct: https://www.schroders.com/en/sustainability/corporate-responsibility/supplier-code-of-conduct/ - Annual Report and Accounts 2021: https://prod.schroders.com/en/sysglobalassets/annual-report/2021/documents/Annual_Report_and_Accounts_2021.pdf

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

Optional comment

We have Employee Handbooks and a Supplier Code of Conduct, which cover these topics.

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

Optional comment

The Group Chief Executive chairs the Corporate Responsibility Committee. We also have other committees and working groups, chaired or attended by Group Management Committee members on all these topics.

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

Optional comment

We have several committees and forums where these topics are discussed including the CR Committee, Human Rights Working Group, Global Employee Forum, Climate Change Working Group and Board Audit and Risk Committee.

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

Optional comment

Human Rights Statement: https://prod.schroders.com/en/sysglobalassets/about-us/group-human-rights-statement-v1_2021_external.pdf Our Modern Slavery Statement can be found in our Reporting Centre and contains details on our due diligence processes related to labour and human rights: https://prod.schroders.com/en/sysglobalassets/digital/global/corporate-responsibility/schroders-plc-modern-slavery-statement-2021.pdf Climate Change Position Statement: https://prod.schroders.com/en/sysglobalassets/about-us/new/planet/group-climate-change-position-statement-2022_ext-26.05.22.pdf

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

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

Optional comment

https://www.schroders.com/en/raising-concerns-in-confidence/. Our Group Whistleblowing Policy (availiable upon request) sets out the internal procedure for reporting and investigating concerns without fear of reprisals or detrimental treatment. We have also extended access to our independently-operated Whistleblowing hotline to any external party.

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

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

Optional comment

in addition, we will review any suspicious/unusual activity/behaviour that the businesses raises; if something has fallen over or we need a stronger control as a result of this investigation we will highlight this to the relevant business areas.

Executive Pay

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

Optional comment

Our executive Directors are assessed against an annual bonus scorecard which includes performance measures on sustainability and risk & conduct. For example in 2021, sustainability included the achievement of environment related measures such as setting science-based emissions targets and publication of our climate transition action outlining our approach towards operating as a net zero business. For 2022 onwards we have also introduced a new climate related measure into the executive Directors Long Term Incentive Plan. In terms of Human Rights, Labour Rights and Anti-Corruption, the performance of the executive Directors is assessed against risk and conduct measures, such as ensuring robust oversight of the Group's activities with no material issues. Were any significant issues or breaches to occur in relation to these topics, we would expect these to be identified through our Group risk adjustment framework and reported to the Remuneration Committee, which would take them into consideration when assessing performance and determining remuneration outcomes for the executive Directors. For further details on our executive Director remuneration approach please see our 2021 Annual Report & Accounts, pages 82-87 (https://prod.schroders.com/en/sysglobalassets/annual-report/2021/documents/Annual_Report_and_Accounts_2021.pdf)

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 (#)	12
Male (%)	50
Female (%)	50
Non-binary (%)	0
Under 30 years old (%)	0
30-50 years old (%)	17
Above 50 years old (%)	83
From minority or vulnerable groups (%)	17
Executive (%)	17
Independent (%)	58

Optional comment

As at 31 December 2021, the Board had three directors (25%) who were executive and not considered independent. We have interpreted “minority or vulnerable groups” to be Schroders plc Board members who have identified to be from an ethnic minority background. For the purpose of this question, and in line with the Parker Review, ethnic minority includes those who identify as: Asian; Black, African or Caribbean; mixed ethnic background; and other ethnic background.

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)

Evidence attached

Limited assurance for majority of metrics

Reasonable assurance for minority of metrics

Reasonable assurance for majority of metrics

Other (Please provide additional information)

Optional comment

AA1000AS Type 2 for operational greenhouse gas emissions.

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
Freedom of expression
Rights of refugees and migrants
Digital security / privacy
2022
Rights of indigenous peoples
Access to culture
Free, prior and informed consent
Access to water and sanitation

Optional comment

Our Group Privacy Policy can be found here: https://www.schroders.com/en/privacy-policy/uk/#:~:text=(3.1)%20Many%20of%20the%20products,Data%20we%20might%20ask%20for. We also have an Information Security and Personal Data Policy which are internal policies. Our Personal Data Policy and Information Security Framework is available on request. Please refer to p. 48 of our Annual Report for a summary of our wider human rights-related policy commitments: https://prod.schroders.com/en/sysglobalassets/annual-report/2021/documents/Annual_Report_and_Accounts_2021.pdf

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

Optional comment

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
We also conducted data protection impact assessments.
Rights of indigenous peoples
Access to culture
Free, prior and informed consent
Access to water and sanitation

Optional comment

In addition to the engagement detailed above: Our public policy engagement with governmental and regulatory bodies stress that environmental, social (such as human rights issues) and governance issues are linked and shouldn't be approached in silos. We strongly believe a more prominent role for social factors and impacts is needed in the regulatory debate, having the potential to provide greater consistency across the finance industry’s definitions of social performance and hence more considerations of issues such as human rights. We engage on the selected human rights issues with our investee companies, these span our human rights, human capital and diversity & inclusion engagement themes. We set out our approach to engagement on these themes in our Engagement Blueprint and report on engagement progress in our quarterly and annual sustainability reports. Our engagement includes identifying what the most material ESG issues are for our investee companies, setting objectives for improvement, maintaining a regular dialogue to discuss progress, and reporting on this.

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

Optional comment

Those who have access credentials to our internal network will receive training on digital privacy.

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

Optional comment

We review issues regularly and set annual goals and track progress over time.

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
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

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.

We have the corporate responsibility to respect human rights, whether in our role as an employer, as a buyer of goods and services or when carrying out our fiduciary duties as a provider of financial services and an investor in companies. We have governance, policies and processes in place to respect human rights and we have implemented remediation processes to deal with any issues raised. Schroders is committed to ensuring that there is no discrimination, including on the grounds of age, disability, gender identity, civil/marital status, pregnancy, maternity, race, religion or belief, sex or sexual orientation during the recruitment process or any stage of the employee lifecycle. Our grievance policies provide a framework for the quick and effective resolution of difficulties that may arise in the workplace and seeks to achieve solutions through appropriate methods. The Group Whistleblowing Policy sets out the internal procedure for reporting and investigating concerns without fear of reprisals or detrimental treatment. Employees are able to raise a concern anonymously to an independent third party, Safecall, who provide a confidential global reporting service through their 24-hour phone line or online portal. More detail on practical actions the company has taken to implement the human rights prinicples can be found in our Human Rights Statement: https://www.schroders.com/en/sysglobalassets/about-us/group-human-rights-statement-v1_2021_external.pdf. Our Modern Slavery Statement, which can be found in our Reporting Centre (https://www.schroders.com/en/investor-relations/results-and-reports/reporting-centre/) also contains details on the practical actions we have taken during the reporting period. We have a dedicated Information Security function responsible for the design and operation of our information security risk framework, which includes oversight of critical third parties’ cyber capabilities. Information security risk is overseen by specialists within both the second and third lines of defence and is monitored by the Information Security Risk Oversight Committee. We benchmark our cyber security capabilities against best practice and in 2021 commissioned an external independent review (further details on page 50). We operate a Global Technology Risk Committee to oversee operational risk associated with IT services across the organisation. The Information Security Risk Oversight Committee sponsored an independent information security review to benchmark the Group’s cyber security capabilities against our peers and industry best practice. The review showed an increase in the maturity of Schroders’ cyber security framework and good progress over the last two years. Attacks by organised crime groups (for example targeted ransomware) remain a risk for financial services and Schroders is no exception. See page 53 of our Annual Report for more detail: https://prod.schroders.com/en/sysglobalassets/annual-report/2021/documents/Annual_Report_and_Accounts_2021.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
2021
Forced labour
2021 for our Human Rights Position Statement. 2022 for our Modern Slavery Statement.
Child labour
2021
Non-discrimination in respect of employment and occupation
2022
Occupational safety and health
2022
Working conditions (wages, working hours)

Optional comment

https://www.schroders.com/en/sysglobalassets/about-us/group-human-rights-statement-v1_2021_external.pdf For more information on our internal policies (including our Inclusion and Diversity and Health and Safety policy), please refer to our latest Modern Slavery Statement which can be found in our Reporting Hub: https://www.schroders.com/en/investor-relations/results-and-reports/reporting-centre/.

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

Group Human Rights Statement https://www.schroders.com/en/sysglobalassets/about-us/group-human-rights-statement-v1_2021_external.pdf. Company's supply chain is included in our Supplier Code of Conduct: https://prod.schroders.com/en/sysglobalassets/digital/global/corporate-responsibility/supplier-code-of-conduct---february-2019.pdf Our Modern Slavery Statement, which can be found in our Reporting Centre (https://www.schroders.com/en/investor-relations/results-and-reports/reporting-centre/) contains details on our policies.

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
Working conditions (wages, working hours)

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
Working conditions (wages, working hours)

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
Child labour
Non-discrimination in respect of employment and occupation
Occupational safety and health
Working conditions (wages, working hours)

Optional comment

Our Modern Slavery Statement and Workforce Diversity Report (all found in our Reporting Centre: https://www.schroders.com/en/investor-relations/results-and-reports/reporting-centre/) provide details on how we assess progress in preventing and mitigating the risks and impacts associated with a number of the below labour rights issues. In regards to health and safety, each location maintains records of training and issues occurring and periodically review them with a view to making continual improvements. Quarterly reports are submitted to provide senior management with a global overview. Whilst each location should set its own targets for improvement global targets are also set.

Performance

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

	Percent of employees (%)	Unknown
Employees covered under collective bargaining (%)	1.6

Optional comment

The percentage provided is in relation to global workforce. Employees covered under collective bargaining agreements apply to our employees based in Luxembourg and France. The Global Employee Forum (GEF) allows us to further gather the views of our people across the firm. The Forum provides a better understanding of important issues such as training and development, performance appraisals and employee opinion surveys. We also have 13 Employee Resource Groups, which are inclusive networks which drive change across our business. They create spaces for employees to network with colleagues passionate about inclusion.

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 (%)	0.1

Optional comment

The percentage provided is in relation to global workforce. This number applies to some of our employees based in Luxembourg who are Trade Union members.

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

	Percent of women (%)	Unknown
Senior leadership level position	33
Non-executive board	50

Optional comment

The % provided in the above is based on representation as at December 2021. Senior leadership level position includes members of the Group Management Committee (GMC), the direct reports of the GMC and the direct reports one level below that, in each case excluding administrative and other ancillary roles.

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 (%)	0

Optional comment

Individuals are remunerated based on the role they perform, irrespective of their gender or other diversity characteristics. As such, men and women performing jobs of equal value are paid equally. However, due to our representation gap in senior roles (see L8) we have a gender pay gap, as explored in our Workforce Diversity and Gender Pay Gap Report 2021 (https://www.schroders.com/en/sysglobalassets/annual-report/2021/documents/schroders-workforce-diversity--gpg-report-2021.pdf)

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	0

Optional comment

We reported no serious injuries as per the gri-403 OHSH standard.

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

	Incident rate	Unknown	Choose to not disclose
Incident rate	0.0009

Optional comment

The number above is an estimation. It has been calculated by dividing the total number of incidents per hour (these were all mental health absences) by our number of employees by an daily average number of working hours in the UK as specified by our Employee Handbooks. We have used the UK as an average as our headquarters as a large proportion of our workforce are UK based.

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.

For more details on practical actions we have taken to implement labour rights principles, please refer to our Reporting hub, where you will find our Modern Slavery Statement, our Annual Report and Accounts (p. 42 - 46) and our Workforce Diversity and Gender Pay Gap Report. Link: https://www.schroders.com/en/investor-relations/results-and-reports/reporting-centre/ Our Group Human Rights Statement also contains details of our practical actions and policies and can be read here: https://www.schroders.com/en/sysglobalassets/about-us/group-human-rights-statement-v1_2021_external.pdf. Change for the better is embedded in our purpose. With every decision, we consider the impact on people. We prize our reputation as an employer of choice and our focus is on empowerment and inclusion. We allow all individuals to have a voice in shaping our culture and believe that it is essential for our employees to be able to thrive every day.

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
2022
Water
2020
Oceans
Forests / Biodiversity / Land Use
2020
Air Pollution
2022
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
2022
Energy & Resource Use
2022

Optional comment

https://www.schroders.com/en/sysglobalassets/about-us/new/planet/group-climate-change-position-statement-2022_ext-26.05.22.pdf https://www.schroders.com/en/sysglobalassets/global-assets/english/campaign/sustainability/integrity-documents/schroders-esg-policy.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

Optional comment

Our company's commitments apply to the investments we manage on behalf of our clients (and including relationships with investees) and our own operations. We have position statements that cover both but policies that are relevant to different parts of the business.

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

In 2021, we conducted over 450 climate-related engagements with our investee companies and voted on over 100 climate-related shareholder resolutions. Furthermore, in January 2021 our CEO, Peter Harrison, wrote to all FTSE 350 companies, urging them to publish detailed transition plans for how they intend to transition their businesses towards net zero emissions by 2050. At the time, around one-sixth of the companies he wrote to had committed to decarbonisation in line with the goals laid out in the Paris Agreement, through science-based targets. Over a year later, this number has doubled, with around one-third of the companies we contacted now having set, or committed to set, a science-based target. https://publications.schroders.com/view/46815205/14/ Throughout 2021, we also engaged with investee companies on the topics of biodiversity and forests, pollution, waste management and energy & resource use. Our Engagement Blueprint outlines Climate Change and Natural Capital and Biodiversity as two of our six priority themes for engagement. See more here: https://www.schroders.com/en/sysglobalassets/about-us/schroders-engagement-blueprint-2022.pdf We record all of our active ownership activities in our in-house database to facilitate the monitoring of companies in which we are invested. To ensure effective monitoring, we define expected timeframes for milestones and goals; track progress against the defined milestones and goals; and revise the goals, if necessary, depending on progress. We review the company’s progress against all engagement asks a year after they have been made, and subsequently on an ongoing basis, recognising that key strategic changes will take time to be implemented into a company’s business process. We recognise that these success factors may be subjective, and that Schroders’ influence may not have been the sole driving force for this change. However, we believe it is important to track companies’ progress and measure the outcomes of our engagement. Operational risks are identified, controlled and mitigated through our ISO 14001 Environmental Management System. Internal and external stakeholders, which can affect the performance of the offices included within our environmental management systsem are engaged to mitigate environmental risks and improve environmental performance. Our office operations have small direct impacts on forests, land use and oceans.

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

Optional comment

We have taken action with key stakeholders to audits our environmental management system for our offices certified through ISO 14001. As a result of this we have developed a corrective action plan to reduce environmental risks and impacts. In order to implement these actions we have collaborated with key stakeholders such as direct employees and suppliers which impact the operations of our offices. Our public policy engagement with governmental and regulatory bodies stressed that the different environmental aspects often interact with each other and hence should be tackled in a comprehensive manner. We strongly believe that an increased policy and regulatory focus on environmental aspects within investment is justified and we welcome additional measures further accelerating a trend we can already recognise with clients demanding more environmental responsibility in their investments.

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

Optional comment

We record all of our active ownership activities in our in-house database to facilitate the monitoring of companies in which we are invested. To ensure effective monitoring, we define expected timeframes for milestones and goals; track progress against the defined milestones and goals; and revise the goals, if necessary, depending on progress. We review the company’s progress against all engagement asks a year after they have been made, and subsequently on an ongoing basis, recognising that key strategic changes will take time to be implemented into a company’s business process. We recognise that these success factors may be subjective, and that Schroders’ influence may not have been the sole driving force for this change. However, we believe it is important to track companies’ progress and measure the outcomes of our engagement. We record all of our active ownership activities in our in-house database to facilitate the monitoring of companies in which we are invested. To ensure effective monitoring, we define expected timeframes for milestones and goals; track progress against the defined milestones and goals; and revise the goals, if necessary, depending on progress. We review the company’s progress against all engagement asks a year after they have been made, and subsequently on an ongoing basis, recognising that key strategic changes will take time to be implemented into a company’s business process. We recognise that these success factors may be subjective, and that Schroders’ influence may not have been the sole driving force for this change. However, we believe it is important to track companies’ progress and measure the outcomes of our engagement.

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	Our net zero commitment spans across both the investments we manage on behalf of our clients and our operations. However, our financed emissions are approximately 6,000 times greater than those from our own business operations, and so the commitments we make across our clients portfolios will be key to contributing to real world emissions reductions. Our net zero commitment is just the first step – we need a plan of action and a way of tracking our progress against it. Our Climate Transition Action Plan outlines the concrete steps we will be taking to meet our targets. The way we will track and be held to account for our progress is through the Science Based Targets initiative (SBTi). In 2021, we committed to align all of our managed assets to a 1.5 degree world by 2040. Our targets have been validated by SBTi, are to reduce the implied temperature of our clients’ portfolios from a baseline of 2.9°C in 2019, to 1.5°C across Scope 1, 2 and 3 emissions in 2040, with an interim target of 2.2°C across Scope 1 and 2 emissions by 2030. Our operational emissions targets, also validated by the SBTi, are as follows: reduce absolute Scope 1 and 2 (location-based) GHG emissions by 46% by 2030 from a 2019 base year, transition to a hybrid or fully electric company car fleet by 2025 (with a strong preference for fully electric unless impractical) with the aim to be fully electric by 2030, increase annual sourcing of renewable electricity to 100% by 2025, reduce absolute business travel GHG emissions by 50% by 2030 from a 2019 base year and work with our suppliers so that 67% of suppliers in scope (by GHG emissions) will have science-based targets by 2026.
Energy & Resource Use	Reduce absolute Scope 1 and 2 (location-based) GHG emissions by 46% by 2030 from a 2019 base year. Increase annual sourcing of renewable electricity to 100% by 2025
Water
Forests / Biodiversity / Land Use	Through the Financial Sector Commitment Letter on Eliminating Commodity-Driven Deforestation, we have committed to using “best efforts to eliminate forest-risk agricultural commodity-driven deforestation activities at the companies in our investment portfolios and in our financing activities by 2025”. We have also joined Natural Capital Investment Alliance, which aims to accelerate the development of Natural Capital as a mainstream investment theme. Its members have plans to launch, or have launched, investment products aligned to Natural Capital themes. These encompass strategies such as direct investments in sustainable forestry and land management.
Air Pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
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
Our Engagement Blueprint contains more detail on our approach to natural capital themes: https://www.schroders.com/en/us/institutional/insights/sustainability/active-ownership-tackles-natural-capital-and-biodiversity/. We also produced the following paper on how we, as a firm, are approaching and reporting progress on natural capital: https://www.schroders.com/en/sysglobalassets/digital/insights/2021/11-november/how-can-investors-assess-impacts-on-nature/603269_sc_in-focus-natural-capital-v04.pdf.
Air Pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Oceans

Optional comment

We provide an update on our progress externally within our Annual Report and Accounts, TCFD-aligned climate report, quarterly and annual Sustainable Investment reports and CDP climate change questionnaire disclosure.

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

Emissions (tCO2e) Scope 1: 1, 980 Scope 2: 3,908 Scope 3: 236,680* The emissions presented above are our total location-based greenhouse gas emissions in 2021 for our operations (it does not include the emissions associated with the investments we manage). The full disclosure can be found on page 47 of our TCFD report (https://www.schroders.com/en/sysglobalassets/annual-report/2021/documents/Schroders_TCFDreport2021.pdf) *We have calculated all relevant Scope 3 emissions therefore there are no exclusions.

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)

As a Financial services firm, we do not we do not directly invest in R&D. In 2021, we announced our investment, with the Oxford Sciences Innovation (OSI) in Natural Capital Research (NCR), a data led science-based organisation which specialises in measuring natural capital assets gloablly. The investment will accelerate the development of NCR’s online platform to map natural capital assets globally, with further investment in leading AI and spatial analytics. With the significant growth in the monitoring and measurement particularly of carbon and biodiversity this platform will become an essential tool for asset owners, asset managers and providers of capital. It also has the potential to validate to the highest standards, nature-based carbon credits and the use of natural capital in flood risk management, water quality and soil improvement. Read more here: https://www.schroders.com/en/media-relations/newsroom/all_news_releases/natural-capital-research-accelerates-global-growth-strategy-with-investment-from-schroders-and-osi/

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

Optional comment

More information can be found in our Climate Transition Action Plan Report (2021) and TCFD 2021 Report available at our Reporting Centre: https://www.schroders.com/en/investor-relations/results-and-reports/reporting-centre/

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

Optional comment

We have committed to the RE100 initiaitve to increase annual sourcing of renewable electricity to 100% by 2025.

Technology

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

Percent of total revenue (%)

Products that promote environmental characteristics or have an environmental objective.

Unknown

Not applicable (Please provide additional information)

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.

In February 2022, the Science Based Targets initiative (SBTi), formally validated our GHG emissions reduction goals. It confirmed that our Scope 1 and 2 targets are in line with a 1.5°C trajectory and that our relevant assets under management (AUM) are also targeted to be fully aligned with a 1.5°C pathway by 2040. We were among the first 20 financial institutions and, at the time, the largest investment manager by AUM, to have its goals formally validated by the initiative. Our TCFD report contains details on our climate targets, metrics and progress: https://www.schroders.com/en/sysglobalassets/annual-report/2021/documents/schroders-tcfd-report-2021.pdf. We have a long history of engagement and voting on climate topics with investee companies. We undertook our first recorded climate engagement in 2002; since then, the scale has risen significantly and similarly, as the number of shareholder resolutions has risen, our voting has followed suit. For more detail on how many climate related engagements we undertook in 2021 please refer to our TCFD report: https://www.schroders.com/en/sysglobalassets/annual-report/2021/documents/schroders-tcfd-report-2021.pdf. For more on our Climate Escalation and Engagement Framework, please refer to our Climate Transition Action Plan: https://www.schroders.com/en/sysglobalassets/digital/global/corporate-responsibility/climate-transition-action-plan.pdf. In terms of our operational environmental impact in 2021, our Scope 1 and 2 emisisons decreased by by 14% compared to 2019 (baseline year). We have increased the percentage of renewable electricity used across our global offices from 50% in 2019 to 84% in 2021. We are a member of RE100 and have committed to sourcing 100% renewable electricity for all of our owned and leased properties by 2025. Our homeworking emissions decreased from 1,838 tCO2e in 2020 to 480 tCO2e and our data showed that fewer of our employees’ homes used gas than estimated in 2020. Our business travel emissions have decreased by 92% compared to 2019 and by 54% compared to 2020 due to the impact of the pandemic on global travel. We do anticipate these will bounce back to a certain extent once travel restrictions are lifted. We continue to operate our business on a climate neutral basis, buying carbon credits equivalent to our greenhouse gas emissions (except supplier and financed emissions where we have engagement targets). For more detail on practical actions we have taken on environment, please refer to our TCFD report and Annual Report and Accounts 2021: https://www.schroders.com/en/sysglobalassets/annual-report/2021/documents/schroders-tcfd-report-2021.pdf and https://prod.schroders.com/en/sysglobalassets/annual-report/2021/documents/Annual_Report_and_Accounts_2021.pdf.

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

Optional comment

We have a number of internal policies and standards relating to anti-corruption and anti-bribery matters that are not published externally. These policies outline our approach to financial crime (including anti-money laundering, counter terrorist financing, anti-bribery, sanctions and tax evasion), inducements, gifts and entertainment, whistleblowing and conflicts of interest. Our Annual Report and Accounts 2021, p. 48, contains more details: https://prod.schroders.com/en/sysglobalassets/annual-report/2021/documents/Annual_Report_and_Accounts_2021.pdf

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

Optional comment

We also see elements picked up via our Audit/Compliance monitoring reviews. This will be on an ad hoc basis.

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
N/A
Confirmed during the current year, and related to this year	0
N/A

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)

Optional comment

We have a number of controls in place that allow us to manage this risk and work with others should we need to do so. If an opportunity for collective action came up, we would review and engage accordingly.

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.

As a firm, we are have zero tolerance to both corruption and bribery. To ensure this is supported throughout the firm, we have a strong framework, policies and procedures in place to manage any risk of bribery and corruption. We issue training annually to raise understanding and awareness and conduct an appropriate level of due diligence on all business relationships to assess and manage the risk of bribery and corruption.