Cambridge Associates ¹ Stewardship and Engagement Policy

Updated September 2025

Summary Statement

CA embeds engagement into our investment practices because it makes us better stewards of capital over the long term and helps us manage systemic risk factors that can manifest at any time. CA seeks to engage with a set of clear principles and priorities and continually raise standards in our processes. We engage asset managers in the same manner that we expect asset managers to engage in dialogue with the underlying companies, issuers, and assets they own to promote clear alignment and allow for effective engagement. Our scale, reputation, and expertise allow us the privilege to push the industry forward through engagement with our asset manager and industry group stakeholders. We recognize the responsibility that we have to our clients as trusted partners to create sustainable value and seek to use the potential of engagement as part of our approach.

What is Stewardship and What is Engagement?

Stewardship is the responsible allocation, management and oversight of capital to create long-term sustainable value for clients and beneficiaries. ²

Engagement puts stewardship into action—it is purposeful dialogue with a specific objective to achieve change, promote disclosure and accountability, and create and preserve value. ³ A clear engagement framework, with specific principles, priorities, and an escalation policy, allows for effective stewardship.

This Policy is an expansion of the Stewardship and Engagement section of Cambridge Associates’ Sustainability and ESG Investment Policy.

How Does Engagement Work Benefit Our Clients?

Cambridge Associates’ (CA) engagement work enables our clients and teams to:

• Add to our understanding of managers’ investment competence and rationale through the way they engage with portfolio companies to impact real-world outcomes and to find differentiated insights.
• Improve client returns by encouraging the use of all relevant information, promoting a focus on the long term, and better identifying the key drivers of thematic risk and return opportunity.
• Cut through the noise and plethora of data to provide relevant, material and decision-useful information for clients and colleagues.
• Enable interested clients to target broader environmental or social impact goals through their investments and to track the results with relevant data.
• Ensure clients can align portfolios with their mission and values, for example by identifying and managing exposures that may impact climate change, a healthy environment, social equity, or thriving communities.

Who Does CA Engage With?

Engaging with asset managers is one of the key stewardship activities CA undertakes to effect positive change and achieve the best outcomes for clients. Asset managers are the counterparties with which we hold the greatest potential scope for influence. CA’s breadth, depth, and scale of relationships with asset managers and our fiduciary duty to clients, presents us with a responsibility that we take seriously. We view our relationship with asset managers as a long-term partnership, and we seek to continually have constructive dialogues with them to explore ways to better meet clients’ evolving needs.

CA engages with asset managers in three specific ways:

1. We assess how investment managers engage with their underlying portfolio companies, debt issuers and assets they own. By meeting regularly with investment managers, our manager research team works to understand their engagement priorities and evaluates them based on CA tools such as the ESG-DEI Manager Assessment Framework (MAF). ⁴

• • We engage with all asset managers to promote transparency and disclosure as well as improvements in corporate governance and decision making. For example, we encourage investment managers to track material environmental, social, and DEI-related metrics and publish relevant reports.
  • We support interested clients in direct engagements with their investment managers and help them participate in collaborative groups of their choosing. One example includes guiding interested clients through the process of supporting shareholder resolutions organized by third-party groups.

2. Our manager research team pursues asset manager engagement in the same manner that we expect asset managers to engage in dialogue with businesses, issuers, and assets they own. We provide them with our feedback and explore ways for them to better align with the key principles of effective stewardship. Our scale and work across asset classes allows us to compare approaches, encourage best practices to be adopted, and help direct capital to market gaps. Given our position in the market we observe high levels of receptiveness to our feedback with most asset managers.
3. CA also collaborates with investor groups and trade associations (such as IIGCC, CFA Institute, ILPA, ICSWG, NZICI and IAA) to support the evolution of industry engagement practices that benefit our clients and to ensure our thinking remains leading edge. We see non-lobbying consultations with policy and regulatory stakeholders as a natural extension of our sustainability commitments. We collaborate to improve disclosure and the spread of best practices where we can add a distinctive voice. Moreover, we similarly encourage collaboration by our managers within their asset class or investor groups to promote more efficient and well-functioning markets. We believe one of our primary value-adds is to bring to the discussion the point of view of long-term investors and practitioners in the marketplace.

Engagement Principles and Priorities

CA’s engagement approach is grounded in three principles, while we currently have three key sustainable and thematic engagement priorities.

The three principles that guide our engagement approach are:

1. Promotion of disclosure and accountability
   • We believe that disclosure and transparency are the basis for sound decision making
   • We engage with managers to encourage disclosure of and accountability for the characteristics of their holdings, investment process and their own operations.
2. Tailored and focused on materiality
   • We believe that engagement needs to be tailored to the specific characteristic of each manager and the specific asks of our clients. For example, our baseline expectation of sustainability reporting from a small early-stage venture capital manager is different from what we expect from a large-cap private equity manager
   • Our engagement focus is driven by financial materiality, by which we mean the relevance and impact of a given factor to investment outcomes.
3. Constructive and outcomes-based approach
   • We seek long-term relationships with asset managers. Successful engagement can take many months, and often years. Engagement is a collaborative, iterative, ongoing activity that is integrated into our overall investment due diligence and ongoing monitoring activity.
   • We believe effective engagement results are best achieved using a constructive rather than a confrontational posture, one that is built on aligned interests, inquiry and advocacy, data- driven advocacy, and mutual benefit to asset managers and asset owners.
   • We prioritize quality over quantity – focusing on selected financially material engagements that will lead to real-world outcomes.
   • We will continuously learn and adapt as we engage and observe initial reactions and outcomes, adjusting our approach to improve our processes and engagement outcomes.

CA’s three current sustainable and thematic engagement priorities:

1. Climate Change and the Transition to Net Zero –Understanding and assessing how asset managers are managing climate change risk and opportunities is key to addressing one of the most critical systemic issues investors face. The financial materiality of the climate crisis requires fiduciaries to protect portfolios from the risks presented by climate change. We engage and assess all asset managers on data disclosure and on the integration of climate considerations into their investment practice, including the encouragement of portfolio companies to set suitable emissions reduction goals. We also engage with multiple investor groups to improve transparency and reporting throughout all asset classes. As a founding member of the Net Zero Investment Consultants Initiative (NZICI) ⁵ , CA made a commitment to support our clients in targeting the real-world reductions of greenhouse gas emissions to net zero by 2050 or sooner, both for their portfolios and the economy at large.
2. Diversity, Equity & Inclusion – We believe that strong investment performance depends in part on the diversity of ideas, backgrounds, networks, and experiences of the managers with whom we invest on behalf of our clients. We assess all managers through this lens, intentionally seeking out managers with diverse perspectives, experiences, backgrounds and innovative thinking.  By engaging in rigorous due diligence and research across an extensive network of global managers, our goal is to increase the breadth of high-conviction investment opportunities for our portfolios, and extensive and differentiated sources of capital, with an eye towards better returns and risk reduction.
3. Governance –We seek to ensure that asset managers have interests that are well-aligned with those of our mutual clients. We engage to ensure that firms are well-structured and resilient throughout evolution and succession, and that teams are well-incentivized and economically aligned. Areas of interest include all firm activities, from investments to portfolio management, operations, fees, terms, and management. Effective engagement generally means collaborating with CA colleagues with expertise in Business Risk Management, Legal and Investment We seek to appropriately address and reduce exposure to headline risk, improper behavior, and unethical behavior.

While the above highlights our current key engagement priority areas, additional areas of focus can arise over time. Our engagements have the aim of improving long-term risk adjusted returns by focusing on material sustainability risks and opportunities and the systemic risks faced by markets. Some additional areas of recent focus have included:

• Client-specific focus issues such as the impact of ultra-fast fashion on the environment and labor;
• Controversies and headline risk such as exposure to holdings where there were cases of ethical breaches;
• Macro events such as, exposure linked to the Russian invasion of Ukraine and the conflict in Israel and Palestine. There is potential for controversies resulting from various dimensions of asset manager activity, sector or thematic characteristics and underlying holding activity. However, we note there is especial potential for risk when these activities intersect with vulnerable populations. Consideration must be given towards human rights risk and ethical considerations as per the UN Global Compact and the UN Guiding Principles on Business and Human Rights. Engagement is encouraged to ensure clarity and disclosure. CA expects adherence with both international and applicable domestic law.

How Do We Integrate Engagement Across Our Investment Platform?

CA has integrated engagement into our manager research and due diligence reports across all asset classes and developed a supporting playbook to help researchers follow through with discussion on engagement priorities. We note that new capital allocation and the due diligence period is a point of strong leverage for an investor. It is an opportunity to ensure there is clear alignment on values and approaches, and that relevant considerations and risks to our clients are well-disclosed. We have formally integrated the following stewardship and engagement practices into our standard manager research process.

1. Assess stewardship and engagement in CA diligence and governance processes: CA’s ESG-DEI Manager Assessment Framework (MAF) evaluates investment strategies across a range of factors including stewardship and This evaluation assesses four key points regarding stewardship and engagement:
   

   Policies & governance	Stewardship and engagement policy stipulates clearly defined engagement priorities. Senior firm leadership have ownership. Engagement has adequate resources (either a separate team or member/members of investment team).
   Communications & transparency	There are data management systems in place to track, assess, and report on engagement activities, progress and voting. Engagement is well-balanced across ESG, DEI, and climate/net zero.
   Investment process	There is an escalation strategy for engagement with portfolio companies. Engagement is part of the total value-add approach. Firm participates in industry collaboration.
   Investment outcomes	Firm can demonstrate improvements in portfolio companies’ ESG, DEI, or other relevant factors. Engagement efforts are sustained at exit (for private investments).

2. Establish engagement priorities: Recognizing the need for continuous improvement, as part of the MAF, each due diligence will include priority topics for engagement over the course of the relationship with the manager. Some topics may be addressed over the short term (less than 12 months), while some topics may be priorities over the medium term (by the next fundraising cycle if a private investment fund), or over the long-term (beyond a fundraising cycle).

How Do We Consider Escalation?

Engagement implies the belief that behavior change by the asset manager is possible to improve investment outcomes. This requires a shared understanding and willingness by both parties to participate. CA may at times engage on challenging topics which require time and a set of tools relevant to the circumstances.

Many engagement topics are centered on open and continued dialogue with managers in meetings, calls, and email correspondence. However, when dialogue stalls, or if there is an unsatisfactory response or fundamental misalignment between the objectives of the manager and asset owner clients, CA may choose to alter tactics and use additional tools (see below) to impress the importance of the topic with asset managers.

In all cases, we suggest dialogue as an initial step to seek positive outcomes, understand manager rationale and encourage accountability for approaches. Some potential additional steps are described in the graphic below; however, we anticipate most CA engagements to oscillate and cycle through the left most stages. Depending on the severity of the engagement topic (e.g., controversies), escalation pathways are not necessarily linear. An investor may jump over some intermediary steps towards greater restrictions if there is a need.

Additionally, we recognize that clients and managers are on a journey, uncovering where material financial risks and opportunities lie over time. This may result in divergence between client and manager objectives. This may be a philosophical divergence, or reputational and/ or financial, ethical and/ or fundamental misalignment such that (further) engagement is likely to be non-productive and an investor decides to reallocate capital towards a more aligned opportunity. Following with our priority of constructive conversation, we encourage the rationale for re-allocation to be disclosed to the manager.

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[1] Cambridge Associates (CA) is a global investment firm subject to various rules, laws and regulations in the jurisdictions in which it operates (“applicable law”). CA seeks to act in accordance and ensure compliance with applicable law.

[2] UK Stewardship Code 2026

[3] Adapted from Investor Forum, The Case for Collective Engagement, 2019

[4] We understand that not all investment managers – such as quantitative or macro asset managers – engage with underlying entities.

[5] Cambridge Associates, Investment Consultants With USD 10 Trillion Of Assets Under Advice Come Together To Launch Global ‘Net Zero’ Initiative, 2021