Engagement Policy Implementation Statement

Introduction

The Trustees of the Wheelabrator Group Pension Scheme (the “Scheme”) have a fiduciary duty to consider their approach to the stewardship of the investments, to maximise financial returns for the benefit of members and beneficiaries over the long term. The Trustees can promote an investment’s long-term success through monitoring, engagement and/or voting, either directly or through their investment managers.

This statement sets out how, and the extent to which, in the opinion of the Trustees, the policies (set out in the Statement of Investment Principles) on the exercise of rights (including voting rights) attaching to the investments, and engagement activities have been followed during the year ending 5 April 2025. This statement also describes the voting behaviour by, or on behalf of, the Trustees including the most significant votes cast during the year, and whether a proxy voter has been used.

The Trustees, in conjunction with their investment consultant, appoint their investment managers (and choose the specific pooled funds to use) in order to meet specific Scheme policies. They expect that their investment managers make decisions based on assessments about the financial (and non-financial performance) of underlying investments (including environmental, social and governance (ESG) factors), and that they engage with issuers of debt or equity to improve their performance (and thereby the Scheme’s performance) over an appropriate time horizon.

The Trustees have decided not to take non-financial matters into account when considering their policy objectives.

Stewardship - monitoring and engagement

The Trustees recognise that an investment manager’s ability to influence the companies in which it invests in will depend on the nature of the investment. The Trustees acknowledge that the concept of stewardship may be less applicable to some of their assets, particularly for short-term money market instruments, gilt and liability-driven investments. As such, the Scheme’s investments in these asset classes are not covered by this engagement policy implementation statement.

Engagement Policy Implementation Statement for the year ending 5 April 2025

The Trustees’ policy is to delegate responsibility for the exercising of rights (including voting rights) attaching to investments to the investment managers and to encourage
the managers to exercise those rights. The investment managers are expected to provide regular reports for the Trustees detailing their voting activity.

The Trustees also delegate responsibility for engaging and monitoring investee companies to the investment managers (and to the investment platform provider, where applicable) and expect the investment managers (and investment platform provider) to use their discretion to maximise financial returns for members and others over the long term.

The Trustees seek to appoint managers that have strong stewardship policies and processes and are supportive of their investment managers being signatories to the

United Nations’ Principles for Responsible Investment and the Financial Reporting Council’s UK Stewardship Code 2020. Details of the signatory status of each investment manager is shown below:

The Trustees review each investment manager prior to appointment and monitor them on an ongoing basis through the regular review of the manager’s voting and a review of each manager’s engagement behaviour. The Trustees may also request their investment consultant’s ESG rating to aide them in this process.

As all of the investments are held in pooled vehicles, the Trustees do not envisage being directly involved with peer-to-peer engagement in investee companies.

Investment manager engagement policies

The Scheme’s investment manager is expected to have developed and publicly disclosed an engagement policy. This policy, amongst other things, provides the Trustees with information on how the investment manager engages in dialogue with the companies it invests in and how it exercises voting rights. It also provides details on the investment approach taken by the investment manager when considering relevant factors of the investee companies, such as strategy, financial and non-financial performance and risk, and applicable social, environmental and corporate governance aspects.

Engagement Policy Implementation Statement for the year ending 5 April 2025 Links to the investment managers’ engagement policies are provided in the Appendix.These policies are publicly available on the investment manager’s website. The latest available information provided by the investment manager (for mandates that contain public equities or bonds) is as follows. Please note that the hedged share classes held by the Scheme hold the same securities as the unhedged share classes.