Engagement Policy Implementation Statement
Wheelabrator Group Pension Scheme
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:
| Investment manager | UN PRI Signatory | UK Stewardship Code Signatory |
| Legal & General Investment Management | Yes | Yes |
| M&G Investment | Yes | Yes |
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.
| Engagement | LGIM North America Equity Index Fund | LGIM Global Emerging Markets Equity Index Fund | LGIM UK Equity Index Fund |
| Period | 01/04/2024-31/03/2025 | 01/04/2024-31/03/2025 | 01/04/2024-31/03/2025 |
| Engagement definition | Purposeful, targeted communication with an entity (e.g. company, government, industry body, regulator) on particular matters of concern with the goal of encouraging change at an individual issuer and/or the goal of addressing a market-wide or system risk (such as climate). Regular communication to gain information as part of ongoing research should not be counted as engagement. | ||
| Number of companies engaged with over the year | 345 | 753 | 204 |
| Number of engagements over the year | 566 | 978 | 362 |
Engagement Policy Implementation Statement for the year ending 5 April 2025 | LGIM Europe (ex UK) Equity Index Fund | LGIM Japan Equity Index Fund | LGIM Asia Pacific (ex Japan) Developed Equity Index Fund |
| Period | 01/04/2024-31/03/2025 | 01/04/2024-31/03/2025 | 01/04/2024-31/03/2025 |
| Engagement definition | Purposeful, targeted communication with an entity (e.g. company, government, industry body, regulator) on particular matters of concern with the goal of encouraging change at an individual issuer and/or the goal of addressing a market-wide or system risk (such as climate). Regular communication to gain information as part of ongoing research should not be counted as engagement. | ||
| Number of companies engaged with over the year | 209 | 122 | 150 |
| Number of engagements over the year | 335 | 186 | 239 |
Engagement Policy Implementation Statement for the year ending 5 April 2025
| Engagement | LGIM FTSE Developed Core Infrastructure Index Fund | M&G Total Return Credit Investment Fund |
| Period | 01/04/2024-31/03/2025 | 01/04/2024-31/03/2025 |
| Engagement definition | Purposeful, targeted communication with an entity (e.g. company, government, industry body, regulator) on particular matters of concern with the goal of encouraging change at an individual issuer and/or the goal of addressing a market-wide or system risk (such as climate). Regular communication to gain information as part of ongoing research should not be counted as engagement. | Interactions between the investor and current or potential investees to influence ESG practices and/or improve ESG disclosure. |
| Number of companies engaged with over the year | 93 | 10 |
| Number of engagements over the year | 155 | 15 |
Exercising rights and responsibilities
The investment managers are expected to disclose annually a general description of their voting behaviour, an explanation of the most significant votes cast and report on the use of proxy voting advisers.
The investment managers publish online the overall voting records of the firm on a regular basis.
The investment managers use proxy advisers for the purposes of providing research, advice or voting recommendations that relate to the exercise of voting rights.
The Trustees do not carry out a detailed review of the votes cast by or on behalf of their investment manager but rely on the requirement for their investment manager to provide a high-level analysis of their voting behaviour.
The latest available information provided by the investment managers (for mandates that contain public equities) is as follows:
| Voting behaviour | LGIM North America Equity Index Fund | LGIM Global Emerging Markets Equity Index Fund | LGIM UK Equity Index Fund |
| Period | 01/04/2024-31/03/2025 | 01/04/2024-31/03/2025 | 01/04/2024-31/03/2025 |
| Number of meetings eligible to vote at | 629 | 5092 | 717 |
| Number of resolutions eligible to vote on | 8278 | 40573 | 10134 |
| Proportion of votes cast | 98.88% | 99.95% | 100.00% |
| Proportion of votes for management | 63.45% | 79.61% | 93.79% |
| Proportion of votes against management | 35.92% | 17.68% | 6.21% |
| Proportion of resolutions abstained from voting on | 0.64% | 2.71% | 0.00% |
| Voting behaviour | LGIM Europe (ex UK) Equity Index Fund | LGIM Japan Equity Index Fund | LGIM Asia Pacific (ex Japan) Developed Equity Index Fund | LGIM FTSE Developed Core Infrastructure Index Fund |
| Period | 01/04/2024-31/03/2025 | 01/04/2024-31/03/2025 | 01/04/2024-31/03/2025 | 01/04/2024-31/03/2025 |
| Number of meetings eligible to vote at | 504 | 493 | 459 | 146 |
| Number of resolutions eligible to vote on | 8539 | 5970 | 3442 | 1870 |
| Proportion of votes cast | 100.00% | 100.00% | 100.00% | 97.91% |
| Proportion of votes for management | 81.54% | 89.87% | 74.52% | 75.20% |
| Proportion of votes against management | 18.05% | 10.13% | 25.31% | 23.81% |
| Proportion of resolutions abstained from voting on | 0.41% | 0.00% | 0.17% | 0.98% |
Trustees’ assessment
The Trustees have undertaken a review of each investment manager’s engagement policy including its policies in relation to financially material considerations.
The Trustees have reviewed each investment manager’s policies relating to engagement and voting and how they have been implemented and have found them to be acceptable at the current time.
The Trustees recognise that engagement and voting policies, practices and reporting, will continue to evolve over time 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.
Engagement Policy Implementation Statement for the year ending 5 April 2025
Appendix
Links to the engagement policies for the investment managers can be found here:
| Investment manager | Engagement policy |
| Legal & General Investment Management | https://am.landg.com/asset/493c9b/globalassets/lgim/_document-library/capabilities/lgim-engagement-policy.pdf |
| M&G Investments | https://group.mandg.com/~/media/Files/M/mandg-corp/corp/documents/how-we-create-value/asset-management/mandg-investments-principles-policies-and-disclosures/mginv-engagement-policy-06-23.pdf |
Information on the most significant votes for each of the funds containing public equities is shown below.
| LGIM | Vote 1 | Vote 2 | Vote 3 |
| UK Equity Index Fund | |||
| Company name | Shell Plc | Unilever Plc | Glencore Plc |
| Date of Vote | 21/05/2024 | 01/05/2024 | 29/05/2024 |
| Approximate size of fund’s holding as at the date of the vote (as % of portfolio) | 770.00% | 420.00% | 230.00% |
| Summary of the resolution | Resolution 22: Approve the Shell Energy Transition Strategy | Resolution 4: Approve Climate Transition Action Plan | Resolution 12: Approve 2024-2026 Climate Action Transition Plan |
| How the fund manager voted | Against | For | Against |
| Where the fund manager voted against management, did they communicate their intent to the company ahead of the vote | LGIM publicly communicates its vote instructions on its website the day after the company meeting, with a rationale for all votes against management. It is their policy not to engage with their investee companies in the three weeks prior to an AGM as their engagement is not limited to shareholder meeting topics. | ||
| Rationale for the voting decision | Climate change: A vote against is applied. We acknowledge the substantive progress the company has made in respect of climate related disclosure over recent years, and we view positively the commitments made to reduce emissions from operated assets and oil products, the strong position taken on tackling methane emissions, as well as the pledge of not pursuing frontier exploration activities beyond 2025. Nevertheless, in light of the revisions made to the Net Carbon Intensity (NCI) targets, coupled with the ambition to grow its gas and LNG business this decade, we expect the company to better demonstrate how these plans are consistent with an orderly transition to net-zero emissions by 2050. In essence, we seek more clarity regarding the expected lifespan of the assets Shell is looking to further develop, the level of flexibility in revising production levels against a range of scenarios and tangible actions taken across the value chain to deliver customer decarbonisation. Additionally, we would benefit from further transparency regarding lobbying activities in regions where hydrocarbon production is expected to play a significant role, guidance on capex allocated to low carbon beyond 2025 and the application of responsible divestment principles involved in asset sales, given portfolio changes form a material lever in Shell’s decarbonization strategy. | Climate change: A vote FOR the CTAP is applied as we understand it to meet LGIM's minimum expectations. This includes the disclosure of scope 1, 2 and material scope 3 GHG emissions and short, medium and long-term GHG emissions reduction targets consistent with a 1.5°C Paris goal. Despite the SBTi recently removing their approval of the company’s long term scope 3 target, we note that the company has recently submitted near term 1.5 degree aligned scope 3 targets to the SBTi for validation and therefore at this stage believe the company's ambition level to be adequate. We therefore remain supportive of the net zero trajectory of the company at this stage. | Climate Change: A vote against is applied as LGIM expects companies to introduce credible transition plans, consistent with the Paris goals of limiting the global average temperature increase to 1.5°C. While we note the progress the company has made in terms of disclosure, we remain concerned over the company's thermal coal activities, as it remains unclear how the planned thermal coal production aligns with global demand for thermal coal under a 1.5°C scenario |
| Outcome of the vote | Pass | Pass | Pass |
| Implications of the outcome | LGIM will continue to engage with our investee companies, publicly advocate our position on this issue and monitor company and market-level progress. | ||
| Criteria on which the vote is assessed to be “most significant” | |||
| Criteria on which the vote is assessed to be “most significant” | Thematic - Climate: LGIM is publicly supportive of so called "Say on Climate" votes. We expect transition plans put forward by companies to be both ambitious and credibly aligned to a 1.5C scenario. Given the high-profile nature of such votes, LGIM deem such votes to be significant, particularly when LGIM votes against the transition plan. | ||
| LGIM | Vote 1 | Vote 2 | Vote 3 |
| Global Emerging Markets Equity Index Fund | |||
| Company name | Tencent Holdings Limited | China Construction Bank Corporation | PDD Holdings Inc. |
| Date of Vote | 14/05/2024 | 27/06/2024 | 20/12/2024 |
| Approximate size of fund’s holding as at the date of the vote | 2.90% | 70.00% | 0.70% |
| Summary of the resolution | Resolution 3a: Elect Charles St Leger Searle as Director | Resolution 10: Elect William Coen as Director | Resolution 6: Elect Director George Yong-Boon Yeo |
| How the fund manager voted | Against | Against | Against |
| Where the fund manager voted against management, did they communicate their intent to the company ahead of the vote | LGIM publicly communicates its vote instructions on its website with the rationale for all votes against management. It is our policy not to engage with our investee companies in the three weeks prior to an AGM as our engagement is not limited to shareholder meeting topics. | ||
| Rationale for the voting decision | Audit Committee: A vote against is applied as LGIM expects the Committee to be comprised of independent directors. Climate Impact Pledge: A vote against is applied as the company is deemed to not meet minimum standards with regard to climate risk management. | Climate Impact Pledge: A vote against is applied as the company is deemed to not meet minimum standards with regard to climate risk management. | Diversity: A vote against is applied as LGIM expects a company to have at least one-third of women on the board. |
| Outcome of the vote | Pass | N/A | Pass |
| Implications of the outcome | LGIM will continue to engage with our investee companies, publicly advocate our position on this issue and monitor company and market-level progress. | ||
| Criteria on which the vote is assessed to be “most significant” | Thematic - Climate: LGIM considers this vote to be significant as it is applied under the Climate Impact Pledge, our flagship engagement programme targeting companies in climate-critical sectors. | Thematic - Climate: LGIM considers this vote to be significant as it is applied under the Climate Impact Pledge, our flagship engagement programme targeting companies in climate-critical sectors. | Thematic - Diversity: LGIM views gender diversity as a financially material issue for our clients, with implications for the assets we manage on their behalf. |
| LGIM | Vote 1 | Vote 2 | Vote 3 |
| North America Equity Index | |||
| Company name | Microsoft Corporation | Amazon.com, Inc. | Alphabet Inc. |
| Date of Vote | 10/12/2024 | 22/05/2024 | 07/06/2024 |
| Approximate size of fund’s holding as at the date of the vote | 560.00% | 3.20% | 2.00% |
| Summary of the resolution | Resolution 9: Report on AI Data Sourcing Accountability | Resolution 6: Report on Customer Due Diligence | Resolution 1d: Elect Director John L. Hennessy |
| How the fund manager voted | For | For | Against |
| Where the fund manager voted against management, did they communicate their intent to the company ahead of the vote | LGIM publicly communicates its vote instructions on its website with the rationale for all votes against management. It is our policy not to engage with our investee companies in the three weeks prior to an AGM as our engagement is not limited to shareholder meeting topics. | ||
| Rationale for the voting decision | Audit Committee: A vote against is applied as LGIM expects the Committee to be comprised of independent directors. Climate Impact Pledge: A vote against is applied as the company is deemed to not meet minimum standards with regard to climate risk management. | Climate Impact Pledge: A vote against is applied as the company is deemed to not meet minimum standards with regard to climate risk management. | Diversity: A vote against is applied as LGIM expects a company to have at least one-third of women on the board. |
| Outcome of the vote | Pass | N/A | Pass |
| Implications of the outcome | LGIM will continue to engage with our investee companies, publicly advocate our position on this issue and monitor company and market-level progress. | ||
| Criteria on which the vote is assessed to be “most significant” | Shareholder Resolution - Governance: A vote FOR this resolution is warranted as the company is facing increased legal and reputational risks related to copyright infringement associated with its data sourcing practices. While the company has strong disclosures on its approach to responsible AI and related risks, shareholders would benefit from greater attention to risks related to how the company uses third party information to train its large language models. | Shareholder Resolution & Human Rights: A vote in favour is applied as enhanced transparency over material risks to human rights is key to understanding the company’s functions and organisation. While the company has disclosed that they internally review these for some products and has utilised appropriate third parties to strengthen their policies in related areas, there remains a need for increased, especially publicly available, transparency on this topic. | Average board tenure: A vote against is applied as LGIM expects a board to be regularly refreshed in order to maintain an appropriate mix of independence, relevant skills, experience, tenure, and background. Diversity: A vote against is applied as LGIM expects a company to have at least one-third women on the board. Independence: A vote against is applied as LGIM expects the Chair of the Committee to have served on the board for no more than 15 years in order to maintain independence and a balance of relevant skills, experience, tenure, and background. Independence: A vote against is applied as LGIM 13 expects the Chair of the Board to have served on the board for no more than 15 years and the board to be regularly refreshed in order to maintain an appropriate mix of independence, relevant skills, experience, tenure, and background. Shareholder rights: A vote against is applied because LGIM supports the equitable structure of one-share-onevote. We expect companies to move to a one-share-onevote structure or provide shareholders a regular vote on the continuation of an unequal capital structure. |
| Outcome of vote | Fail | N/A | Fail |
| Implications of the outcome | LGIM will continue to engage with their investee companies, publicly advocate their position on this issue and monitor company and market-level progress. | ||
| Criteria on which the vote is assessed to be “most significant” | High Profile meeting: This shareholder resolution is considered significant due to the relatively high level of support received. | Pre-declaration and High-Profile Meeting: This shareholder resolution is considered significant as one of the largest companies and employers not only within its sector but in the world, we believe that Amazon’s approach to human capital management issues has the potential to drive improvements across both its industry and supply chain. LGIM voted in favour of this proposal last year and continue to support this request, as enhanced transparency over material risks to human rights is key to understanding the company’s functions and organisation. While the company has disclosed that they internally review these for their products (RING doorbells and Rekognition) and has utilised appropriate third parties to strengthen their policies in related areas, there remains a need for increased, especially publicly available, transparency on this topic. Despite this, Amazon’s coverage and reporting of risks falls short of our baseline expectations surrounding AI. In particular, we would welcome additional information on the internal education of AI and AI-related risks. | Thematic - Diversity: LGIM views gender diversity as a financially material issue for our clients, with implications for the assets we manage on their behalf. Thematic - One Share One Vote: LGIM considers this vote to be significant as LGIM supports the principle of one share one vote. |
| LGIM | Vote 1 | Vote 2 | Vote 3 |
| Europe (ex UK) Equity Index | |||
| Company name | Nestle SA | TotalEnergies SE | EssilorLuxottica SA |
| Date of Vote | 18/04/2024 | 24/05/2024 | 30/04/2024 |
| Approximate size of fund’s holding as at the date of the vote | 290.00% | 170.00% | 70.00% |
| Summary of the resolution | Resolution 7: Report on Non Financial Matters Regarding Sales of Healthier and Less Healthy Foods | Resolution 6: Reelect Patrick Pouyanne as Director | Resolution 11: Elect Francesco Milleri as Director |
| How the fund manager voted | For | Against | Against |
| Where the fund manager voted against management, did they communicate their intent to the company ahead of the vote | LGIM publicly communicates its vote instructions on its website with the rationale for all votes against management. It is our policy not to engage with our investee companies in the three weeks prior to an AGM as our engagement is not limited to shareholder meeting topics. | ||
| Rationale for the voting decision | Shareholder proposal & Health & Nutrition: A vote FOR is applied. LGIM is one of the co-filers of this resolution. We call for more effective targets to increase the availability of healthier food choices for consumers. There is a clear link between poor diets and chronic health conditions such as obesity, heart disease and diabetes. These in turn may lead to increased healthcare costs and decreased productivity, both of which we believe will have negative impacts on the economy. As the largest food company in the world we believe Nestle sets an example for the rest of the industry in terms of driving positive change and raising market standards. | Joint Chair/CEO: A vote against is applied as LGIM expects the roles of Board Chair and CEO to be separate and not to be recombined once separated. These two roles are substantially different and a division of responsibilities ensures there is a proper balance of authority and responsibility on the board. | Joint Chair/CEO: A vote against is applied as LGIM expects the roles of Board Chair and CEO to be separate and not to be recombined once separated. These two roles are substantially different and a division of responsibilities ensures there is a proper balance of authority and responsibility on the board. |
| Outcome of the vote | N/A | N/A | N/A |
| Implications of the outcome | LGIM will continue to engage with our investee companies, publicly advocate our position on this issue and monitor company and market-level progress. | ||
| Criteria on which the vote is assessed to be “most significant” | Pre-declaration and High-Profile Meeting: This shareholder resolution is considered significant due to nutrition being an important topic for investors because it has a significant impact on the health and well-being of individuals, communities and societies. The interconnected challenges of obesity, undernutrition and micronutrient deficiencies is estimated to be 5% of global income, or $3.5 trillion, per annum. Nutrition is therefore one of our global stewardship sub-themes, under the umbrella of Health. | Thematic - Board Leadership: LGIM considers this vote to be significant as it is in application of an escalation of our vote policy on the topic of the combination of the board chair and CEO. | Thematic - Board Leadership: LGIM considers this vote to be significant as it is in application of an escalation of our vote policy on the topic of the combination of the board chair and CEO. |
| LGIM | Vote 1 | Vote 2 | Vote 3 |
| Japan Equity Index | |||
| Company name | Toyota Motor Corp. | KEYENCE Corp. | Shin-Etsu Chemical Co., Ltd. |
| Date of Vote | 18/06/2024 | 14/06/2024 | 27/06/2024 |
| Approximate size of fund’s holding as at the date of the vote | 520.00% | 180.00% | 140.00% |
| Summary of the resolution | Resolution 1.1: Elect Director Toyoda, Akio | Resolution 2.2: Elect Director Nakata, Yu | Resolution 2.2: Elect Director Saito, Yasuhiko |
| How the fund manager voted | Against | Against | Against |
| Where the fund manager voted against management, did they communicate their intent to the company ahead of the vote | LGIM publicly communicates its vote instructions on its website with the rationale for all votes against management. It is our policy not to engage with our investee companies in the three weeks prior to an AGM as our engagement is not limited to shareholder meeting topics. | ||
| Rationale for the voting decision | Independence: A vote against is applied due to the lack of independent directors on the board. Independent directors bring an external perspective to the board. Bringing relevant and suitably diverse mix of skills and perspectives is critical to the quality of the board and the strategic direction of the company. We would like to see all companies have a third of the board comprising truly independent outside directors. Diversity: A vote against is applied due to the lack of meaningful diversity on the board. Climate Impact Pledge: A vote against is warranted as we believe there is still a disconnect in Toyota's stated climate ambitions and its current multi pathway strategy. We encourage Toyota to further develop disclosures that more clearly articulate how it intends to support a global transition to zero emission vehicles and net zero emissions. Accountability: A vote against has been applied as the Company has not provided disclosure surrounding the use of former CEO as Advisor to the Board. Additionally, a vote AGAINST Mr Toyoda is warranted because, as a long time top executive, Mr Toyoda should be considered ultimately accountable for a spate of certification irregularities within the Toyota Motor group. We are concerned that previous and current issues concerning legal certifications processes and safety requirements are indicative of a corporate culture that is not being amended to meet stakeholder expectations and legal requirements. For this reason, Mr Toyoda must be held accountable until appropriate remediation measures are taken. | Diversity: A vote against is applied due to the lack of meaningful diversity on the board. Accountability: A vote against has been applied as the Company has not provided disclosure surrounding the use of former CEO as Advisor to the Board. | Diversity: A vote against is applied due to the lack of meaningful diversity on the board. |
| Outcome of the vote | N/A | N/A | N/A |
| Implications of the outcome | LGIM will continue to engage with our investee companies, publicly advocate our position on this issue and monitor company and market-level progress. | ||
| Criteria on which the vote is assessed to be “most significant” | Thematic - Diversity: LGIM views gender diversity as a financially material issue for our clients, with implications for the assets we manage on their behalf. Thematic - Climate: LGIM considers this vote to be significant as it is applied under the Climate Impact Pledge, our flagship engagement programme targeting companies in climate-critical sectors. | Thematic - Diversity: LGIM views gender diversity as a financially material issue for our clients, with implications for the assets we manage on their behalf. | Thematic - Diversity: LGIM views gender diversity as a financially material issue for our clients, with implications for the assets we manage on their behalf. |