Eurosif Transparency Guidelines

Insight is a signatory to The Eurosif Transparency Guidelines for the Retail SRI Sector.

Eurosif, the European Social Investment Forum, is a non-profit membership organisation that promotes the concept, practice and development of sustainable and responsible investment. In November 2004, Eurosif launched its voluntary Transparency Guidelines, which are intended to help consumers understand the SRI policies and practices of individual SRI funds in order to maintain and increase consumer confidence. The guidelines were developed through a multi-stakeholder consultation that incorporated the views of the financial services community, research groups NGOs, trade unions and others. Insight actively contributed to this process, including piloting the guidelines in 2003/2004. (Please see Eurosif’s website for more details.)

Insight strongly welcomes this initiative. We believe it provides much needed and long overdue transparency for the sector. We hope that other fund managers will follow our lead in becoming signatories.

Statement of Commitment to the Transparency Guideline Requirements

Insight is fully committed to transparency. This is evidenced by our extensive disclosure on our company engagement activities, as well as by our commitment to the development and implementation of the Eurosif Transparency Guidelines. We have endeavoured to answer each guideline question openly and honestly and believe that our response is consistent with best practice in this sector. However, we feel that it is the role of our clients and other stakeholders to form an independent view regarding the extent of our compliance with the guidelines.

Questions and/or comments regarding Insight’s response to The Eurosif Transparency Guidelines for the Retail SRI Sector may be directed to investor_responsibility@insightinvestment.com.

Updated June 2006

Insight’s Response to The Eurosif Transparency Guidelines for the Retail SRI Sector

Section 1 Basic Details - Signatories should be clear about who they are and provide background information on the fund, and the fund manager.

Section 2 SRI Investment Criteria - Signatories should be clear about their purpose and investment criteria.

Section 3 Research Process - Signatories should provide information on their research process.

Section 4 Evaluation and Implementation - Signatories should provide information on how the research is used to build and maintain their portfolio.

Section 5 Engagement Approach - Signatories should explain their approach to engagement if the fund has such a policy.

Section 6 Voting Policy - Signatories should make clear their policies on voting.

Section 7 Periodic Activities - Signatories should periodically disclose information about their activities.

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Questions and/or comments regarding Insight’s response to The Eurosif Transparency Guidelines for the Retail SRI Sector may be directed to investor_responsibility@insightinvestment.com.