BTPS Sustainability Policy The purpose of this document is to articulate BT Pension Scheme’s (“BTPS” and the “Scheme”) approach to sustainability across the Scheme’s assets 1. Approach Developing from the Hermes Responsible Ownership Policyi, the BTPS Sustainability Policy applies across all asset classes and markets in which we invest. The Trustee has a fiduciary responsibility to meet the Scheme's liabilities and as a long term asset owner considers sustainable factors to improve long term risk adjusted returns. BTPS is a founder signatory of the UN-backed Principles for Responsible Investment (PRI) initiativeii which forms the basis of this Policy. The Trustee is committed to its membership and active support of the organisation and we encourage our managers and fellow pension funds to sign and implement the PRI. 2. Oversight and reporting Our sustainable activities are overseen by the BTPS Trustee via the Policy Committee, a sub committee of the Trustee Board. The Policy Committee will review the sustainability policy annually and recommend to the Trustee Board and/or Investment Committee appropriate actions We will report on details of our sustainability activities, including voting and engagement data, in the BTPS annual report and accounts and on the BTPS website. 3. Influence As a universal asset owner the value of our investments are closely tied to the economy as a whole. To protect and enhance the Scheme’s long-term value as well as reduce risk, it is in our beneficiaries interests to raise standards across the whole market by engaging with policymakers, regulators and governments to encourage them to address failures as well as consideration of new policies and policy direction. We also acknowledge our leadership position and aim to leverage this as one of the UK’s largest DB corporate pension schemes. We will collaborate with other institutional investors where possible to influence best practice, and enable us to strengthen the voice of asset owners. 4. Asset allocation We endeavour to allocate capital to investment conduits which are well aligned to BTPS’ requirements. This should include investments in sustainable themes. We will regularly monitor the sustainability of our investments in terms of size, quantum of risk and reputational risk. 5. Our investment managers All parts of the investment chain which work on the behalf of the Scheme should be aligned to our beneficiaries interests. Both individually and working with industry groups we seek to enhance best practice and alignment of our agents and hold them accountable.iii. We also encourage all our investment managers to give due consideration to and report on sustainable factors which could be material to the long-term value of our investments. BTPS will assist, encourage and challenge managers to improve the quality of their integration of environmental, social and corporate governance factors into investment processes and reporting. 6. Stewardship We strive to be active asset owners across all asset classes and have developed a comprehensive stewardship policyiv. Outside of listed markets we will encourage our managers to monitor and engage investment partners and portfolio companies. 7. Engagement We publicly endorse the FRC’s UK stewardship code and support the development of similar codes around the world to encourage active ownership by all asset owners. We will adopt a collaborative and thematic approach to our corporate engagements whilst always being mindful of the objectives of our corporate sponsor, BT plc, and other potential conflicts of interest (for example, where we are both equity and bond holders of the same company). Engagement priorities and themes are overseen centrally by BTPS and activities are outsourced to our engagement service provider. Where appropriate we will encourage our investment managers to integrate the results of our engagement activity into their investment process. 8. Voting We aspire to vote all of our directly held equities and bonds. BTPS, via its outsourced voting provider, will support the recommendations of a company’s board unless it has a good reason not to do so. Please refer to the BTPS voting policy for further detailv. Version 3.0 April 2013 i Available at http://www.hermes.co.uk/Portals/8/The_Hermes_Ownership_Principles_UK.pdf ii The Principles were devised by the investment community to reflect the view that sustainability factors can affect the portfolio performance and must be given appropriate consideration by investors if they are to fulfil their fiduciary (or equivalent) duty. Assets under management by PRI signatories is more than $32 trillion. iii See ICGN Model Mandate Initiative http://www.icgn.org/files/icgn_main/pdfs/drafts/mmi_consultation_31jan2011.pdf iv http://www.btpensions.net/153/267/frcs-uk-stewardship-code v http://www.btpensions.net/151/voting-disclosure