Training 2000 Limited Retirement and Death Benefit Scheme Implementation Statement

Introduction

The Trustees have reviewed the extent to which their policy relating to the exercise of rights (including voting rights) attaching to the investments was followed over the Scheme Year and this statement confirms the outcome of that review.

In addition, the statement summarises the voting record of the Scheme’s investment managers and provides information on the significant votes made in respect of the Trustees' equity holdings. Information is also provided on how the Scheme’s investment managers make use of the services of proxy voting advisers.

The Trustees' Policy Relating to the Exercise of Rights

Summary of the Policy

The Trustees' policy in relation to the exercise of rights (including voting rights) attaching to the investments is set out in the SIP. The SIP was updated during the Scheme year to reflect changes made to the Scheme’s investment strategy, but wording relating to the exercise of rights was not revised. A summary of this wording is as follows:

• The Trustees believe that good stewardship can help create, and preserve, value for companies and markets as a whole and the Trustees wish to encourage best practice in terms of stewardship.
• The Trustees invest in pooled investment vehicles and therefore accept that ongoing engagement with the underlying companies (including the exercise of voting rights) will be determined by the investment managers' own policies on such matters.
• When selecting a pooled fund, the Trustees consider, amongst other things, the investment manager’s policy in relation to the exercise of the rights (including voting rights) attaching to the investments held within the pooled fund.
• When considering the ongoing suitability of an investment manager, the Trustees (in conjunction with their Investment Adviser) will take account of any particular characteristics of that manager’s engagement policy that are deemed to be financially material.
• The Trustees will normally select investment managers who are signatories to the UNPRI.
• If it is identified that a fund’s investment manager is not engaging with companies the Trustees may look to replace that fund. However, in the first instance, the Trustees would normally expect their Investment Adviser to raise the Trustees' concerns with the investment manager.

Has the Policy Been Followed During the Scheme Year?

The Trustees' opinion is that their policy relating to the exercise of rights (including voting rights) attaching to the investments has been followed during the Scheme Year. In reaching this conclusion, the following points were taken into consideration:

• There has been no change to the Trustees' belief regarding the importance of good stewardship.
• The Scheme’s invested assets remained invested in pooled funds over the period.
• During the Scheme Year, the Trustees introduced an allocation to the Insight Longer Real and Insight Longer Nominal funds. The Trustees considered the ESG characteristics of the fund before selecting it but, because the fund does not include an allocation to equities consideration of the exercise of voting rights was not relevant.
• In addition, during the Scheme Year, the Trustees introduced an allocation to the LGIM FW Global Equity Index Fund and the LGIM FW Global Equity Index Fund - GBP Currency hedged. The Trustees considered the ESG characteristics of the funds before selecting them and this included consideration of the investment manager’s approach towards the exercise of voting rights.
• During the Scheme Year, the Trustees considered the voting records of the Scheme’s investment managers over the period ending 30 June 2021.
• Since the end of the Scheme Year, an updated analysis of the voting records of the investment managers based on the period ending 30 June 2022* has been undertaken as part of the work required to prepare this Implementation Statement. A summary of the key findings from that analysis is provided below.
• The investment managers used by the Scheme are UNPRI signatories.

*Note the voting analysis was over the year ending 30 June 2022 because this was the most recent data available at the time of preparing this statement. The Trustees are satisfied that the analysis provides a fair representation of the investment managers' voting approach over the Scheme Year.

Use of Proxy Voting Advisers

Voting in Significant Votes

Based on information provided by the Trustees' Investment Adviser, the Trustees have identified significant votes in nine separate categories. The Trustees consider votes to be more significant if they are closely contested. i.e. close to a 50:50 split for and against. A closely contested vote indicates that shareholders considered the matter to be significant enough that it should not be simply “waved through”. In addition, in such a situation, the vote of an individual investment manager is likely to be more important in the context of the overall result.

The five most significant votes in each of the nine categories based on shares held by the Scheme’s investment managers are listed in the Appendix. In addition, the Trustees considered each investment manager’s overall voting record in significant votes (i.e. votes across all stocks not just the stocks held within the funds used by the Scheme).

Conclusion

Based on the analysis undertaken, the Trustees have no material concerns regarding the voting records of Baillie Gifford or LGIM.

The Trustees will keep the voting actions of the investment managers under review.

Signed: Lisa Bloomfield
Date: 14 February 2023

Signed on behalf of the Trustees of the Training 2000 Limited Retirement and Death Benefit Scheme