Code de Transparence17

2015
Asset management
ESG Questionnaire
UBS (Lux) Equity Fund – Global Sustainable
ESG Questionnaire 2015
1 The Fund Management Company

1.1 Provide the name of the fund management company managing the fund(s) to which
this code applies.
Fund management company:

UBS Fund Management (Luxembourg) S.A.
33A avenue J.F. Kennedy
L-1855 Luxembourg
Portfolio manager
UBS Global Asset Management (Americas) Inc
One North Wacker Drive
Chicago, IL 60606
Telephone: +1-312-525 7100
www.ubs.com
1.2 Describe the general approach of the fund management company with regards to how
it takes environmental, social and governance (ESG) criteria into consideration.
Is the fund management company approach towards ESG criteria aligned or inspired by
its corporate social responsibility approach? Yes/No. If yes, insert a link to the
company’s CSR policy. If not, explain why not.
Yes. UBS and its business groups are firmly committed to corporate responsibility and actively
strive to understand, assess, weigh and address the concerns and expectations of the firm’s
stakeholders. This process supports UBS in its efforts to safeguard and advance the firm’s
reputation for responsible corporate conduct. In very direct ways, responsible corporate conduct
helps create sustainable value for the company.
Please refer to the UBS Corporate Responsibility website for further details:
http://www.ubs.com/global/en/about_ubs/corporate_responsibility.html
Has the fund management company signed the Principles for Responsible Investment? If
yes, please insert the link to the answer to the PRI questionnaire. If not, explain why
not.
Yes. UBS Global Asset Management became a signatory to the United Nations Principles for
Responsible Investment (UNPRI) in April 2009. We do not make our answers to the PRI
questionnaire publicly available. However, the following document explains how we are
implementing the Principles.
http://www.ubs.com/global/en/asset_management/responsible_investment/unpri.html
Asset Management Page 2 of 19

Does the fund management company apply any exclusion in its general investment
process, for example related to the manufacture, maintenance and trade of
controversial arms?
Yes. Under the UBS Sanctions Policy, business activities concerning certain countries, regimes or
named individuals are restricted. All measures outlined in the UBS Sanctions Policy apply globally
throughout the entire UBS Group irrespective of whether the local country has imposed any such
sanctions.
In addition, UBS complies with the revised Swiss Federal Act on War Materials, which bans the
use, stockpiling, production and transfer of cluster munitions and anti-personnel mines. The Swiss
law integrates and goes beyond the Oslo convention banning cluster munitions and anti-
personnel mines (hereinafter referred to as “controversial weapons”), to include the ban on
direct and indirect financing of controversial weapons. In effect, the ban prohibits the range
activities ranging from provision of credit facilities, capital market transactions, to the buying and
holding of equity and/or bonds (including derivatives thereof) of companies that are involved in
the development, production or purchase of controversial weapons. The ban does not prohibit
business relationships with executives of such companies.
Based on this regulation and awareness of the potentially significant damage to its reputation
when supporting companies which are involved in Controversial Weapons, UBS will not directly
or indirectly finance companies involved in the development, production or purchase of cluster
munitions and anti-personnel mines of such companies determined to fall within the ban. This
will include terminating the holding of any long or short positions in securities of such companies
in its proprietary trading book or to include them in its actively-managed retail and institutional
funds and in discretionary mandates.
Is the fund Manager a signatory or a member of other international and/or national
initiatives supporting SRI practices? Please answer if you deem this information to be
useful.
UBS has endorsed and signed several charters, including UN Global Compact, the UNEP Finance
Initiative and the Wolfsberg Group. UBS is a member of further organizations that promote
corporate responsibility and is actively engaged in their activities. Please refer to the UBS
Corporate Responsibility webpage for more details.
http://www.ubs.com/global/en/about_ubs/corporate_responsibility/commitment_strategy/external
/further_commitments.html

Has the fund management company established an ESG engagement policy? If yes,
describe the policy by outlining its objectives and its methodology and/or, if it is public,
insert a link to the policy. If not, explain why not.
Yes, for our equity investments, our written corporate governance principles apply globally. We
believe voting rights have economic value and should be treated accordingly. Where we have
been given the discretion to vote on clients' behalves, we exercise our delegated fiduciary
responsibility by voting in a manner we believe will most favourably impact the economic value of
their investments. We vote globally so long as there is no conflict with the efficient management
of client portfolios.
On behalf of our clients, we aim to be supportive, long-term shareholders. We seek to develop
both a long-term relationship and an understanding of mutual objectives and concerns with the
companies in which we invest on behalf of our clients. Through regular meetings (around 7 000
globally each year) we make an assessment of management performance and monitor
development over time. In the year to 31st December 2014, we voted at 7 325 company
meetings globally on a total of 74 655 separate resolutions. We declined to support management
on 5 246 or some 7% of these resolutions.
Engagement with company management on environmental, social and governance issues is
undertaken by our own investment professionals to varying degrees according to local
customs/regulations. Our Corporate Governance Director leads our governance engagement with
companies and works closely with the in-house analysts and portfolio managers. We maintain a
comprehensive database of our governance engagements, votes cast and the reasons for voting
against management or abstaining.
As a general rule we believe the effectiveness of such policies is considerably increased when we
find common ground with other shareholders. We are thus willing to work with collective bodies,
such as the ABI Investment Committee, or collaborate with other major shareholder groups if we
believe this will increase the chance of success. We are also members of the Conference Board's
Council on Corporate Governance, which brings together asset managers and companies for
constructive debate.

Has the fund management company established a voting policy? If yes, describe the
policy by outlining its objectives and its methodology and/or, if it is public, insert a link
to the policy. If not, explain why not.
Yes. We believe voting rights have economic value and should be treated accordingly. Where we
have been given the discretion to vote on clients’ behalves, we will exercise our delegated
fiduciary responsibility by voting in a manner we believe will most favourably impact the
economic value of their investments.
Good corporate governance should, in the long term, lead towards both better corporate
performance and improved shareholder value. Thus, we expect board members of companies in
which we have invested to act in the service of the shareholders, view themselves as stewards of
the company, exercise good judgment and practice diligent oversight of the management of the
company. A commitment to acting in as transparent a manner as possible is fundamental to
good governance.
In serving the interests of our clients, some investment capabilities within UBS Global Asset
Management may at times pursue differing approaches towards particular corporate governance
issues, including how to vote or abstain on proposals. This reflects the diverse nature of our
capabilities.
However, in all cases the interests of clients will be paramount. Underlying our voting and
corporate governance principles we have two fundamental objectives:
 We seek to act in the best financial interests of our clients to enhance the long-term value of
their investments.
 As an investment advisor, we have a strong commercial interest that companies in which we
invest, on behalf of our clients are successful. We promote best practice in the boardroom.
To achieve these objectives, we have established a set of Principles to guide our exercise of voting
rights and the taking of other appropriate actions, and to support and encourage sound
corporate governance practice. These Principles are applied globally but also permit us the
discretion to reflect local laws or standards where appropriate.

While there is no absolute set of standards that determine appropriate governance under all
circumstances and no set of values will guarantee ethical board behaviour, there are certain
principles, which provide evidence of good corporate governance. We will, therefore, generally
exercise voting rights on behalf of clients in accordance with the following principles:
Board Structure
Some significant factors for an effective board structure include:
 An effective Chairman is key.
 The roles of Chairman and Chief Executive generally should be separated.
 The Board should be comprised of individuals with appropriate and diverse experience
capable of providing good judgment and diligent oversight of the management of the
company.
 The non executive directors should provide a challenging, but generally supportive
environment for the executive directors.
Board Responsibilities
Some significant factors for effective discharge of board responsibilities include:
 The whole Board should be fully involved in endorsing strategy and in all major strategic
decisions (e.g., mergers and acquisitions)
 The Board should ensure that at all times:
 Appropriate management succession plans are in place.
 The interests of executives and shareholders are aligned.
 The financial audit is independent and accurate.
 The brand and reputation of the company is protected and enhanced.
 A constructive dialogue with shareholders is encouraged.
 That it receives all the information necessary to hold management to account.
Describe how the fund management company or the group contributes to the
promotion and the development of SRI.
UBS has a company-wide commitment to leading-edge sustainability research and initiatives
across all of its divisions. This includes the UBS Investment Bank’s award-winning sustainability
research unit, UBS Wealth Management’s thematic research team and UBS Global Asset
Management’s Sustainability Equities team.
In addition, UBS is a leader in advancing sustainability analysis with its membership in two key
steering committees, the Sustainability Accounting Standards Board and the Global Initiative for
Sustainability Ratings. Shawn Lytle, Head of UBS Global Asset Management in the Americas was
recently added to the SASB (Sustainability Accounting Standards Board).

1.3 Describe/List your SRI products and the specific resources allocated to your SRI activities.
Briefly describe the SRI fund range (number, assets under management, strategies,..)
In addition to the UBS (Lux) Equity Fund – Global Sustainable, we offer a number of other
sustainable equity strategies:
As at 31 March 2015, we managed a total of 1 042 million USD in dedicated Sustainable / SRI
strategies.

Describe/Detail the resources allocated by the fund management company

(organisation, ESG research internal/external, dedicated portfolio management team,…)
and indicate where this information is available.
Sustainable & Responsible Investments (SRI) team
We have a dedicated Sustainable Investors team comprised of two portfolio managers and two
equity strategists, who manage a range of strategies that integrate material sustainability factors
with a rigorous fundamental investment process. The team is headed by Bruno Bertocci, who has
34 years of equity investing experience. Investment themes include energy efficiency,
environment, social improvement and health care and demographics. The team is also supported
by the wider Equities platform and is able to draw on the work of our sector analysts worldwide.
Corporate Governance
Ian Pitfield is Corporate Governance Director, responsible for setting and implementing UBS
Global Asset Management’s corporate governance and SRI policy, working closely with the
investment teams. Ian has wide investment experience both as an analyst and portfolio manager,
and has worked at UBS Global Asset Management since 1986. Ian leads our global voting team
and the engagement on corporate governance with the companies in which UBS Global Asset
Management invests on behalf of clients.
Ian is a member of the ABI Investment Committee, the International Corporate Governance
Network, the Conference Board’s Council on Corporate Governance and the CFA Society of the
UK. He was a member of the CFA Institute global corporate governance taskforce and chaired
the NAPF Case Committee on Shell.
Paul Clark, who joined UBS Global Asset Management in 1994, is Head of Corporate Governance
Services, and is responsible for a team of three that handle the day-to-day aspects of voting and
background research to company meetings. Paul has managed the team since 2000 and has
been involved in portfolio services since 1987. He is also a member of the International Corporate
Governance Network.
The Corporate Governance team is part of our Equities investment area and is responsible for
voting for all clients globally in all worldwide markets. The only exception to this will be locations
where legal restrictions prevent us from either voting for clients, or do not allow voting powers to

be exercised outside the local jurisdiction. This approach has enabled us to ensure that our
corporate governance and voting service is integrated and closely aligned with our investment
teams and ensures that we have a consistent, robust process when acting for our clients.
Describe the content, frequency and resources allocated/used by the fund management
company to inform investors about the ESG criteria taken into account.
UBS strives to report openly and transparently about the firm's corporate responsibility strategy
and activities both via a section in the UBS Annual Report and, in more detail, on the UBS
corporate responsibility website. Additional relevant information is provided in an employees
section in the annual report and on the UBS employees website.
We use the Global Reporting Initiative (GRI) as the basis for our corporate responsibility reporting
and apply a careful process weighing up the materiality and relevance of the information
reported and the expectations of all our stakeholders.
UBS's reporting has been reviewed by Ernst & Young Ltd (EY) against the GRI Sustainability
Reporting Guidelines. The content has been prepared in accordance with the comprehensive
option of GRI G4 as evidenced in the EY assurance report. This assurance was conducted by EY.
http://www.ubs.com/global/en/about_ubs/corporate_responsibility/information-
center.html#par_title_6
1.4 Provide the name of the fund(s) to which this Code applies and its (their) main
Characteristics
Describe the main characteristics of the fund(s): geographical focus, asset class, SRI
strategy used (use the classification provided by Eurosif/EFAMA).
The UBS (Lux) Equity Fund – Global Sustainable invests worldwide in companies that generate
above-average environmental, social and governance performance and offer interesting growth
potential. It is an all-cap strategy that seeks to access the full range of sustainable investment
opportunities, allocating approximately 80% to large caps, up to 10% to mid-caps and 10% in
small caps. These proportions will vary depending on our assessment of relative return
opportunities.

While the strategy is benchmark-aware, the sizing of positions is dependent on relative

opportunity, which means that the largest positions in the portfolio are often small- or mid-cap
stocks that we believe provide superior return opportunity. The full market cap universe allows
investors to potentially benefit from broad diversification, strong fundamental analysis and
valuation, as well as a thematic component.
1.5 What is (are) this (these) fund(s) trying to achieve through taking into account ESG
criteria?
For instance, financing a specific sector, reducing risks, support better CSR practices,
develop new value creation opportunities, other objectives. If part of the fund(s) assets
is invested in unlisted organisations with high social, community or impact investing
relevance, please specify.
The Global Sustainable Strategy is a positive screening portfolio. We have a negative screening
process that excludes companies that have more than 5% of revenues in alcohol, tobacco,
defence, nuclear, GMO, water bottles, gambling and pornography from the portfolio. But the
most important screening is positive in nature, seeking companies that are fundamentally
attractive, have superior valuation characteristics and that have a positive business model that can
benefit from sustainability trends. We have four broad themes; energy efficiency, environmental,
health care and social improvement in which we seek beneficiaries. All of the stocks held in the
Global Sustainable Strategy are grouped into one of these four themes: energy efficiency
(29.3%), environmental (22.1%), healthcare (15.0%) and social improvement (33.6%) – data as
at 31 March 2015. Our thematic weights are a result of our bottom-up stock opportunities and
we are not trying to target a certain weight in each theme.

2 Approach to ESG Evaluation of Companies

2.1 What fundamental principles underlie the ESG research methodology?
Describe the principles, standards or norms on which the ESG analysis is based for each
of the environmental, social/societal and governance dimensions. Include brief
comments about how stakeholders are consulted, as appropriate.
Our investment philosophy and process combine our bottom-up fundamental research with
rigorous sustainability analysis. We actively look for companies that appear attractively valued and
can benefit from secular themes, such as energy and water conservation, health care,
demographics and other long-term trends. Sustainability has emerged as arguably the largest
growing consideration as companies look to achieve long-term viability and profitability.
Shareholders own much more than a company’s financial statement - they have invested in
management, buildings, employees culture, regulatory environment, governance and brand
equity. We look at the whole picture when making investment decisions.
Createimpact
Create impact and
and returns
returns
Growth, social responsibility and ecological sustainability are elements of
winning business models
 We believe that you can do good while you do well

 We believe that companies focusing on sustainability strengthen their competitive
position and have superior business models
 We believe that sustainable growth trends are in their infancy and present
investment opportunities
 We believe that companies offering sustainable solutions create value
 We believe that a deep focus on understanding value chains will deliver investment
results
 We believe in bottom-up, high-conviction “best ideas” strategies
Sustainable
fundamentals
+ Attractive
valuation
+ Portfolio
construction = Sustainable 
Source: UBS Research Focus 2006
US-I 8
We use a company-wide valuation model to make our projections as comparable as possible.

Through this process, we aim to identify the best investment ideas across sectors and
geographies from a stock-specific standpoint. This component of the process provides strong
traditional valuation support to our stock selection strategy.
The portfolio management team integrates these inputs into a best ideas portfolio of stocks that
we believe are attractively valued and that have a strong sustainability profile. In doing so, the
team draws upon its members’ years of experience and utilizes the firm’s proprietary risk
management tools.
2.2 What internal and external resources are used to carry out this research?
Describe the general information used to carry out the ESG research: internal analysis,
ESG rating agencies, other external sources of information.
The Sustainable Equities Team leverages the firm's global analyst research platform as well as
portfolio construction and risk tools. In addition, our Sustainable Equities strategies benefit from
the ongoing development of a proprietary database of fundamental sustainability metrics. This is
a collaborative effort with our Applied Research Team and it provides the team with a significant
competitive advantage.

We also use industry surveys and glean information from external sources. Our team of investors
also stress-tests sell-side broker financial models. The facts finding process, Sustainability checks,
and fundamental analysis for the Global Sustainable strategy are performed internally.
The team also has access to many external fundamental ESG data sources including rating
services such as MSCI ESG, Sustainalytics, Sustainability, Reprisk, and Governance Metrics. In
addition we have access to sustainability research from brokers and data providers such as
Bloomberg ESG data. UBS Global Asset Management also has a regular dialogue with
sustainability experts from many organizations including Deloitte Consulting, Accenture
Consulting, the Sustainability Accounting Standards Board, NGOs, and other sustainability
organizations.
The strategy also benefits from a company-wide commitment to leading-edge sustainability
research and initiatives across all of UBS's divisions. This includes the UBS Investment Bank's
award-winning sustainability research unit as well as UBS Wealth Management's thematic
research team. In addition, UBS is a leader in advancing state-of-the-art sustainability analysis
through its membership in two key steering committees: the Sustainability Accounting Standards
Board and the Global Initiative for Sustainability Ratings.
2.3 Which ESG analysis criteria are used?
Indicate what the main criteria for each of the environmental, social/societal and
governance dimensions are. Specify if these criteria differ according to sectors, the
geographical zones, and the type of company… If appropriate, provide an example.
Socially Responsible Investing (SRI) is historically associated with negative screening. The most
common screens (including ours) excludes companies with more than 5% in sales in defence,
GMO, tobacco, alcohol, nuclear, gambling, adult entertainment and water bottles. Because these
excluded companies are limited to about 7% of the ACWI universe, their exclusion does not
materially affect investment results or our process.
We believe that ESG factors are best assessed as part of the company research process. These
factors are fundamental in nature and need to be analyzed as an integral part of the due
diligence process, included in our estimation of cash flows and valuation metrics. Our proprietary
analysis covers each of the environmental, social and governance dimensions to arrive at an
overall ESG score for each company:

While we do not have a “check list” approach, we have identified industry group-specific Key
Performance Indicators (KPIs) which are weighted according to their importance for the sector.
Please find below an example of the KPIs that we analyse for companies in the Auto industry:
Each KPI is converted into a score using the weightings and a final score for the company is then
calculated. In theory our scores would be 0 to 100, but in practice the maximum score is currently
87 and this will change over time as the scores get updated. The rankings are broken into deciles
and it is important to note that these are industry group relative. So the breakdown of score
ranges will be different for each industry group. Each decile or bucket will have about the same
number of companies. This allows us to systematically focus on the most attractive stocks in our
universe from a valuation and sustainability perspective at the same time.

At this time UBS is working with several external organizations as well as its own quantitative
teams to build a quantitatively-driven ESG framework. This framework will eventually assemble
our internal data, external data from vendors and databases into a factor matrix that will allow us
to develop and backtest ESG ratings and factors for investment effectiveness. We believe that this
effort will further enhance our ability to have a proprietary and fundamental view of ESG factors
at the company level.
2.4 What is your ESG analysis and evaluation methodology (how the investment universe is
built, rating system…)?
Describe the ESG evaluation/rating system and how it is built by explaining how the
various ESG criteria are articulated. If appropriate, provide an example.
We have a negative screening process that excludes companies with more than 5% of revenues
in alcohol, tobacco, defence, nuclear, GMO, water bottles, gambling and pornography from the
portfolio. But the most important screening is positive in nature, seeking companies that are
fundamentally attractive, have superior valuation characteristics and that have a positive business
model that can benefit from sustainability trends.
We do not rely on outside ratings although we consult a diverse set of external inputs to ensure
that our own fundamental ESG assessment is reasonable. In some cases we have found that
external databases are out of sync with forward-looking assessments, either maintaining a high
rating when we believe the company is deteriorating in its ESG policy, or maintaining a low rating
when the management has made significant changes in ESG policy. We therefore rely on our
proprietary analysis which covers each of the environmental, social and governance dimensions to
arrive at an overall ESG score for a company. Please refer to our response to question 2.3 for a
more detailed description of this process.
It is important to understand that we are not using the sustainability score as a single basis for
decision making. Rather, we are comparing candidates for the portfolio that have both strong
valuation and sustainability criteria and we are looking at the sustainability data in detail to
compare the relative strength and weaknesses of companies. The sustainability score is a
simplifying initial step that enables us to prioritize our entire research universe.
UBS Global Asset Management‘s Applied Research unit in conjunction with outside experts has
built a leading edge database of fundamental sustainability data at the company and industry
group level that is used alongside valuation data from our analysts to rank the investment
universe on both fundamental and sustainability attractiveness. The database parallels the
approach taken by the Sustainability Accounting Standards Board in building its Materiality
Matrix™. We believe that this database is unique and gives us a significant proprietary edge in
the incorporation of fundamental, material sustainability data in the investment process. This
Sustainability KPI (key performance indicator) database is instrumental in ensuring that both
valuation and sustainability factors are taken into account simultaneously and that both receive
equal weighting in the decision making process.
2.5 How frequently is the ESG evaluation reviewed?
Please briefly explain the methodology update process and who is involved. If
appropriate, explain if the methodology has changed in the past 12 months and the
nature of the key changes.
The Sustainable Equity Team reviews the sustainability ratings on a weekly basis. The
sustainability ratings are not changing on a weekly basis, but our valuation rankings may change
frequently with price changes in the markets. That is why we review the ratings weekly at our
team meeting. See also answer to question 2.4 above which explains that we have built out a
leading edge database of fundamental sustainability data.

3 Fund Management Process

3.1 How do you take into account ESG criteria when defining the universe of eligible
investments?
If appropriate, describe the eligibility threshold and the resulting level of selectivity.
At the outset, we consider the full universe as defined by the MSCI ACWI index. We apply a
negative screen excluding controversial companies with more than 5% of sales in defence, GMO,
tobacco, alcohol, nuclear, gambling, adult entertainment and water bottles. These exclusions
comply with the United States Conference of Catholic Bishop's (USCCB) Socially Responsible
Investment Guidelines. These exclusions represent around 7% of the ACWI universe.
We perform a positive screening, seeking companies that are fundamentally attractive, have
superior valuation characteristics and that have a positive business model that can benefit from
sustainability trends.
Source: UBS Global Asset Management, 2014
3.2 How do you take ESG criteria into account into the portfolio construction?
Describe how you link ESG selection with the financial analysis or with portfolio
management. More precisely, describe how the results of the analysis of each of the
dimensions (E, S and G) are integrated into the investment / divestment process. If
applicable, state where you provide information on divestments occurred in the past
year on the basis of ESG criteria? If appropriate, explain how potential ESG weightings
are defined and describe your treatment of companies that are not subjected to an ESG
analysis.
Our objective is to invest in companies that meet three important criteria:
 First, the stock must be fundamentally attractive from a conventional valuation standpoint.
 Second, we invest in companies that have strong, above-average, forward-looking ESG
profiles. We do not rely on outside ratings although we consult a diverse set of external
inputs to ensure that our own fundamental ESG assessment is reasonable. In some cases we
have found that external databases are out of synch with forward-looking assessments, either

maintaining a high rating when we believe the company is deteriorating in its ESG policy, or
maintaining a low rating when the management has made significant changes in ESG policy.
 Finally, we invest in companies that have strong business models that can benefit from
Sustainability trends. We believe that companies with strong shared values with the
surrounding community can achieve a meaningful long-term competitive advantage.
This process is depicted in the graph below.
We use Key Performance Indicators to score companies in our universe. In theory our scores
would be 0 to 100, but in practice the maximum score is currently 87 and this will change over
time as the scores get updated. The rankings are broken into deciles and it is important to note
that these are industry group relative. So the breakdown of score ranges will be different for each
industry group. Each decile or bucket will have about the same number of companies. This allows
us to systematically focus on the most attractive stocks in our universe from a valuation and
sustainability perspective at the same time. Generally speaking, we only invest in companies that
are ranked in the 6th decile or above, both in terms of valuation and sustainability. This allows us
to systematically focus on the most attractive stocks in our universe from a valuation and
sustainability perspective at the same time.
Companies that no longer fulfil our ESG or valuation criteria are sold as soon as practical,
depending on liquidity and trading volume.
3.3 Does (do) the fund(s) have a specific ESG engagement policy?
Please explain what you mean by engagement. Describe how you select the companies/
themes for engagement activities and the impact on the portfolio management of the
fund(s). Who undertakes engagement on behalf of the fund (internal and/or service
providers)?
We are actively engaged with companies across a wide range of issues including ESG. UBS
Global Asset Management votes all of its shares across the firm except for those accounts that
are client-directed. Our Global Director of Governance manages engagement on behalf of the
firm and publishes an annual report on Governance activities. Please refer to our “Annual
Corporate Governance review” on the following link:
http://www.ubs.com/global/en/asset_management/responsible_investment.html

3.4 Does (do) the fund(s) have a specific voting policy integrating ESG criteria?
Yes/No
No. Our voting policy applies globally. Please refer to the description of our voting policy in
question 1.2.
3.5 Does (do) the fund(s) engage in securities lending activities?
If yes, (i) is a policy to recall the securities in place in order to exercise the voting rights ?
The fund may lend portions of its securities portfolio to third parties. In general, lending may only
be effected via recognized clearinghouses such as Clearstream International or Euroclear, or
through the intermediary of prime financial institutions that specialize in such activities and in the
modus specified by them. Such transactions may not be entered into for longer than 30 days,
however. If the loan exceeds 50% of the securities portfolio of the fund, it may only be affected
on condition that termination of the loan contract is possible immediately.
We believe that voting rights have economic value and should be treated accordingly. Our
Corporate Governance team under Ian Pitfield is responsible for setting and implementing UBS
Global Asset Management's corporate governance principles. As such, this team determines
whether or not it is relevant to recall a stock from loan in order to exercise voting rights. If
deemed relevant, the team will notify the Board of Directors of the fund. It is then for the Board
of the fund to decide whether to recall the stock dependent on whether they believe that the
issues being voted upon are of sufficient importance to offset the economic benefit of the loan.
(ii) does the counterparty selection process integrate ESG criteria ?
UBS operates securities lending on the principal basis, i.e. for every lending transaction only UBS
AG is the counterparty of the investment fund and guarantees all claims of the fund. As such, no
research is conducted into the ESG characteristics of the counterparty.
With regards to broker selection, this is primarily based on best execution criteria. Where multiple
counterparties offer equivalent best execution, then consideration may be given to research
provided and this may include work on ESG. However, ESG characteristics at the individual
counterparty corporate level are not directly a factor in counterparty selection.
3.6 Does (do) the fund(s) use derivative instruments?
If yes describe,
(i) their nature
(ii) the objective(s)
(iii) the potential limits in terms of exposure
(iv) if appropriate, their impact on the SRI quality of the fund
The fund may, while observing the following investment principles, buy or sell futures and
options on financial instruments or conduct transactions for non-hedging purposes involving
options on securities. These market techniques and instruments will only be employed if they are
in conformity with the investment policies and do not adversely affect their quality.
The use of derivatives has no influence on the SRI quality of the fund. Derivatives are mainly used
to manage cash holdings.
For further details, please refer to the fund prospectus.
3.7 Is a share of the fund(s) invested in unlisted entities pursuing strong social goals?
If yes, please provide a brief description of the objective(s) of this investment, in no
more than one or two sentences.
No.

4 Controls and ESG Reporting

4.1 What internal/external control procedures are in place to ensure the compliance of the
portfolio with the ESG rules defined in section 3 of this Code?
State who is carrying out the controls, their frequency and within which timeframe the
fund(s) have to comply should a breach be detected.
Controls are carried out on an ongoing basis by the investment team. When a company faces
controversy, we would analyse the event and then decide if we sell out of our position and if we
engage with the company. The decision of which action to take depends on our assessment of
how the stock price would be affected in the future. If we felt that the controversy is likely to
deteriorate and the stock price will fall, then we may sell out of our position.
4.2 Please list all public media and documents used to inform investors about the SRI
approach to the fund, and include URLs. This should include a link to the detailed, no
more than 6 months old, list of holdings of the fund(s).
X Prospectus
X (semi-) Annual report
X Addendums
X KIID
X Fund Fact Sheet
http://bw.fundgate.ubs.com/fistructures.do?lang=fr&instid=304&qsearch=eco&cty=FR&rid=16
X Dedicated SRI Web page(s) at company / fund level (if applicable)
X Engagement/voting policy/votes (if applicable)
http://www.ubs.com/1/e/globalam/responsible_investment.html.
X Link to Web page of ESG Analysis provider(s) (if applicable):
https://esgmanager.msci.com/esgmanager/
https://login.sustainalytics.com/Login.aspx
We also get ESG ratings information from Bloomberg, Reuters, and Goldman Sachs.
X URL to the research findings that are available to investors (if appropriate) Not available
X Detailed fund holdings (no more than 6 months old)
X CSR Policy of the Company l (if applicable)
http://www.ubs.com/1/e/globalam/responsible_investment.html.
Additional
If applicable, specify what the amount of donations and the percentage of management
fees that the fund gave to charities in the last year.
Not applicable.

T
The present document is for information purposes and internal use only. This document has been prepared by CCR Asset
Management, a public limited company (Société Anonyme) with capital of 5 304 000 Euros, and registered offices at 44 rue
Washington, 75008 Paris - France (registered under number 388 368 110 of the Paris commercial register, RCS) authorised
as a portfolio management company by the French financial markets authority (Autorité des Marchés Financiers) on 30
November 1992 under number GP 92016. CCR AM is the representative in France of UBS Global Asset Management. This
document is intended for institutional investors and distribution partners. It in no way constitutes an offer, or a request-
for-proposal, and it does not constitute advice to buy or sell an investment or specific product in any jurisdiction. Although
this document has been prepared with the greatest care using sources that CCR Asset Management esteems to be reliable,
no guarantee can be offered as to the accurate and exhaustive nature of the information and evaluations contained
within the document, which are of only purely indicative value. CCR Asset Management declines all responsibility
regarding any investment or divestment decisions which may have been taken on the basis of data included in this
presentation. Prior to any subscription, the legal information documents for each product should be consulted (full
prospectus, latest annual report) as well as the latest periodic publication. This information can be obtained freely by
accessing our Internet website: http://www.ccr-am.com. These documents, which include information concerning risks,
commissions and costs, can also be obtained upon simple written request to the following address: CCR Asset Management
- Washington Plaza - 44, rue Washington - 75008 Paris - France. CCR Asset Management draws your attention to the fact
that the value of a unit of an ICVC or a mutual fund unit is subject to financial market movements and recorded value
therefore fluctuates. Any investment in UCITS incurs risk for the investor of a greater or lesser degree based on investment
markets, including the risk of total and sudden loss of the investment. Past performances are not a guarantee of future
performance. The present document has been established independently from any specific or future investment objectives,
from any specific financial or fiscal situation, and from any experience or understanding of financial products or needs
pertaining to any individual addressee. The SICAV / FCP is offered solely to investors that are not U.S. Persons (as defined in
the US regulation and in the Prospectus of the SICAV / Fund) under the terms and conditions of the current prospectus of
the SICAV / FCP. Unless prior authorisation has been obtained from CCR Asset Management: total or partial reproduction
on any support; communication to third parties; use for any purposes other than private use; or alteration of brand names,
logos, illustrations, analyses, distinguishing features, images, animations, graphs, photographs or texts which may be
included in this presentation is not permitted and liable to prosecution.
CCR Asset Management

44 Rue Washington
75008-Paris
www.ccr-am.com

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2015

1 The Fund Management Company

Fund management company:

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Describe/Detail the resources allocated by the fund management company

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While the strategy is benchmark-aware, the sizing of positions is dependent on relative

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2 Approach to ESG Evaluation of Companies

 We believe that you can do good while you do well

We use a company-wide valuation model to make our projections as comparable as possible.

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3 Fund Management Process

Source: UBS Global Asset Management, 2014

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4 Controls and ESG Reporting

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CCR Asset Management

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