SOCIALLY RESPONSIBLE INVESTING POLICY

Overview

MacKay Shields LLC and MacKay Shields UK LLP (collectively, “MacKay Shields”) are proud signatories of the Principles for Responsible Investment (“PRI” or “Principles”), in recognition of the impact that we believe environmental, social and governance (“ESG”) issues can have on long-term investment performance.

The Principles

The PRI provides a framework for incorporating ESG considerations into investment and ownership practices. In becoming a PRI signatory, each of MacKay Shields’ investment teams commits to the following six aspirational principles where consistent with our fiduciary duty to clients:

Principle 1: Incorporate ESG issues into investment analysis and decision-making processes.

Principle 2: Be active owners and incorporate ESG issues into ownership policies and practices.

Principle 3: Seek appropriate disclosure on ESG issues by the entities in which we invest.

Principle 4: Promote acceptance and implementation of the PRI within the investment industry.

Principle 5: Work together to enhance our effectiveness in implementing the PRI.

Principle 6: Report activities and progress toward implementing the PRI.

Our Approach

Socially Responsible Investing Advisory Committee. MacKay Shields has established an advisory committee charged with overseeing our commitment to the Principles. The committee includes senior level representation from each of our portfolio management teams and non-investment groups. Members of the Committee meet regularly to:

• Discuss approaches to implementing ESG into the investment process;

• Share information on ESG developments;

• Discuss third party ESG products and tools; and

• Conduct and promote ongoing ESG training

Thought Leadership

Members of MacKay Shields’ Socially Responsible Investing Advisory Committee have been active in promoting thought leadership on ESG-related issues.

• Young Lee (Chair), Won Choi (High Yield Team), and Michael Kimble (Global Fixed Income Team) contributed to a seminal report published by the PRI in April 2018 titled “ESG Guidance for Fixed Income Investors: Managing Risks, Enhancing Returns”.

• Young Lee is a co-author of “Corporate Governance and ESG: An Introduction” that is part of the CFA Level 1 curriculum.

• Young Lee has been tasked by the CFA Institute to author a companion piece on Corporate Governance and ESG that will soon be part of the CFA Level 2 curriculum.

ESG Training

In recognition that best practices in ESG integration are continuously developing, MacKay Shields’ investment professionals participate in ESG-related training programs.

Reporting

As part of our commitment as a signatory, the firm report on our ESG activities to the PRI on an annual basis.

An Ongoing Commitment

We are committed to strengthening and refining our ESG approach through continued dialogue with industry experts, assessing third party ESG-related analytical tools and resources, participating in ESG training, and conducting regular meetings of the Socially Responsible Investing Advisory Committee to augment our ESG-related reporting and research processes and to document existing activities.