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A time for action

Race, ethnicity and investing

In a two-part feature, we look at what asset managers need to focus their engagement efforts on to make a difference on anti-black racism, and why the industry needs to get its own house in order.

Worldwide demonstrations following the brutal deaths in 2020 of three black Americans, George Floyd (46), Breonna Taylor (26) and Ahmaud Arbery (25), have been a wake-up call for many companies, opening the eyes of white employees – and senior management – to the fact racism is still present in most businesses.

Although investor engagement has helped drive change on many fronts in recent years, from climate change to gender diversity, the harsh reality is that it has had far less impact on racial inequality. But why is this, and what needs to change for engagement to have a more substantial and lasting influence?

“The first thing is to recognise we have a problem and a collective responsibility to work towards a solution,” says Mirza Baig, global head of governance at Aviva Investors. “We need to ensure the diversity agenda is expanded to fully reflect the spectrum of marginalised communities.”


Ignorance is no excuse

Diversity has been on the corporate agenda for years, with companies keen to talk up their equal opportunity hiring and diversity and inclusion (D&I) initiatives. Yet while overt racism is perhaps less prevalent in the workplace than it once was, racial discrimination has not been eradicated.

This is evident in the way black people are underrepresented at senior levels in many businesses. And yet many white employees of those same businesses will be unaware of the problem.

Four main factors are at play in maintaining this state of ignorance. First, it can be extremely hard for black employees to speak out. Because they can be few and far between in some companies, and tend to occupy junior or middle management positions, they may struggle to make themselves heard.

Many white people remain unaware of their white privilege

Second, many white people remain unaware of their white privilege – the ability to live their lives without having to think about how their skin colour affects the way they are treated. They may become uncomfortable and defensive when talking about racism and discrimination – US academic Robin DiAngelo sees this response as evidence of “white fragility” – preventing open dialogue on the issues.

Third, ethnic diversity has often been left behind as D&I projects have focused on gender, and black people have been categorised alongside Asian minorities in inclusion initiatives under the BAME acronym. This has hidden the ongoing underrepresentation of black employees, particularly at senior levels. As of October 2019, there were only six black CEOs among S&P 500 companies, and 37 per cent of those firms did not have a single black board member.1

“We need to ensure that when we say black, we mean black, not BAME,” explains Elizabeth Atoyebi, associate for infrastructure equity at Aviva Investors. “There are a lot more ‘palatable’ demographics in BAME, and some people say they want to see more BAME representation because they don’t want to say ‘black’.”

Figure  1:  Ethnic minority representation in FTSE 100 companies in 2019
Ethnic minority representation in FTSE 100 companies in 2019
Source: ‘Leadership 10,000 2019,’ Green Park, December 4, 2019. Note: White: white; Ethnic: black African, Caribbean, black British, Pakistani, Bangladeshi, Arab, Indian, Chinese, any other Asian. Black: black African, Caribbean, black British; Top 3: Chair, CEO and CFO; Top 20: Board, including Chair, CEO and CFO plus the Executive Committee; Top 100: senior leaders who report into the Top 20

Fourth, the issue is compounded by class discrimination in many blue-chip companies. Class is another critical barrier to being hired and promoted, and black minorities in Europe and the US are, on average, from less privileged backgrounds.2

These factors help explain why, despite well-meaning talk at a high level, there has been no real progress in the participation and promotion of black employees.

59 per cent of FTSE 350 company boards still have no ethnic minority representation today

“Whether it is specifically in terms of black people or more broadly people from ethnic minorities, few companies have set targets,” says Marte Borhaug, global head of sustainable outcomes at Aviva Investors. “A good example was the Parker Review in 2017, which said every FTSE firm should have at least one ethnic minority board member by 2021 – not the most ambitious target, but at least it made some recommendations. Yet 59 per cent of FTSE 350 company boards still have no ethnic minority representation today. That’s not good enough. We need to see firms being clear about what they’re aiming for and when they will deliver.”3

Helping to remove the “kinks in the hosepipe”

Dawid Konotey-Ahulu, co-founder of the investment consultancy Redington and the #TalkAboutBlack initiative in the investment industry, likens the difficulties faced by young and talented black professionals to “kinks in the hosepipe” that stop their careers from flowing. These range from socioeconomic differences to entry-level barriers, discrimination in career progression and the fact the problem has traditionally been low on company boards’ agendas.4

“In the past, I had never had a conversation about the B in BAME, and even the broader BAME conversation was a bit of a tick-box exercise. Companies certainly didn’t take it as seriously as focusing on margins or their strategy for developing new products. This needs to be elevated to the same level,” says Konotey-Ahulu.

He advocates two key actions to help change company culture. First, companies should open the discussion on race internally across the firm. Second, and perhaps most importantly, those in senior management positions should take it upon themselves to understand the problem and what they can do to address it.

Senior management has to go on a learning process, understanding what it is like to be black

“Senior management has to go on a learning process, understanding what it is like to be black, and what the kinks in the hosepipe are. It’s like anything; to be an expert on climate or a strategic initiative, you’ve got to go and learn about it,” explains Konotey-Ahulu.

While the investment industry itself has considerable room for improvement, as we highlight in part 2, asset managers also face increasing pressure from clients to demonstrate effective engagement with companies in other sectors, as well as governments, non-government organisations and industry bodies.

This is crucial; to effect change, senior executives need to connect the issue of racial discrimination to their own business. According to Baig, many companies simply don’t recognise their power to be an agent for change through relations with suppliers, staff, consumers and society.

“We need to help them – and us – recognise their role, understand where they are on the journey, set targets and ambitions and translate those into policies and initiatives,” he says.

It will be a learning process, but Borhaug says we can take a lot from what has been done on gender. “We didn’t make real progress until we started taking meaningful action, for example with countries imposing quotas of women on boards and investment firms changing their voting policies. We now need to take the same kind of action for black representation in the workforce and the boardroom,” she says.

Five key areas for engagement

To incorporate black representation more explicitly into Aviva Investors’ own engagement strategy, Borhaug and Baig have identified a framework around five key areas.

“First, we expect companies to create an inclusive culture for black employees. Firms should commit publicly to a D&I agenda that includes a focus on ethnic minorities, with policies in place to promote inclusion and tackle discrimination of all kinds, including on race,” says Borhaug.

Firms should commit at board level to zero tolerance of harassment and bullying

“More specifically, firms should commit at board level to zero tolerance of harassment and bullying. In the UK, for instance, we expect companies to sign up to the Race at Work Charter, which has seen more than 190 companies in the UK sign up since its launch in October 2018,” she adds.

This may not seem like much, but research shows not all leaders are ready to take even this minimal step. The UK 2018 Race at Work Report found only one in three employees surveyed said there was at least one senior leader or champion in their organisation who actively promoted equality, diversity and fairness, showing no change since 2015.5

In addition to public commitment and policies, research and stakeholder interviews frequently highlight the need for financial support for initiatives aimed at tackling racism at work, including dedicated roles, programmes, events and other activities. Although employee networks play a crucial role, companies should ensure they are properly resourced. To that end, Aviva Investors is encouraging investee companies to dedicate time and money to such initiatives.

The second point focuses on representation at a senior level. “We will be asking companies to commit to ethnic minority representation, including black representation, on boards and in senior management teams,” says Borhaug. “We need to rethink how we are holding those companies to account in terms of representation.”

Aviva recently became a founding member of Change the Race Ratio, a campaign led by the Confederation of British Industry to encourage companies to improve the representation of black and ethnic minorities in their organisation. By signing up, companies commit to setting targets for their boards and senior management teams.

The third area involves diversity proofing business strategies. Across the globe, but even in white-majority countries, black consumers form a large part of the customer base, and firms should be thinking about how to satisfy their needs with products and services.

Research by PwC demonstrates the value of this approach. In 2018, it analysed the D&I strategy of 50 businesses, including leadership tone, HR policies and whether there were any D&I initiatives. The research found that the most successful firms had a D&I strategy alongside a closely aligned corporate strategy.6

It is good practice for firms to assess risks associated with racial discrimination

Another aspect is the importance of embedding the risks stemming from racial discrimination into the enterprise risk management framework. Companies manage a variety of business-related risks, including climate change and staff retention. It is good practice for firms to include risks associated with racial discrimination, enabling them to recognise, measure, understand and tackle them.

The fourth area of engagement involves putting pressure on companies to review HR policies and practices, from identifying and recruiting talent to creating a level playing field for promotion and improving retention. In a 2018 update to the McGregor-Smith Review, over half of BAME employees felt they would have to leave their organisation to progress their careers, compared with 38 per cent of white employees.7

Finally, companies will be called on to collect relevant data, set targets and measure progress. “You need data to be able to hold companies accountable: when engaging with them, we are somewhat hamstrung by the lack of it,” says Baig. This is true for diversity in general, but even more so for black representation.

Figure  2:  Percentage of European and American firms disclosing
Percentage of European and American firms disclosing…
Source: JP Morgan, Bloomberg. Europe: Bloomberg Europe 500 firms; USA: S&P 500 firms

Holding companies accountable

While there is an ethical imperative to act, companies that fail to address the issues in their own organisations could quickly find there are financial consequences. David Cumming, chief investment officer for equities, and Colin Purdie, chief investment officer for credit at Aviva Investors, believe companies that don’t change will be shunned by consumers and investors.

In a recent BBC interview, Cumming cited Facebook as an example of a company that has seen a hit to its reputation and advertising revenues through failing to address hate content on its platform. Up until last year, content from white supremacists could still be posted, while racist adverts were still appearing until recently.

Companies that don’t change will be shunned by consumers and investors

He said: “They have got no real HR framework to govern their approach to free speech at the moment, and their current defence around impartiality and complaining about the lack of regulation is viewed as an abdication of responsibility.”8,9

At least some businesses are waking up to the issue. Baig notes some retailers have started to proactively allocate 15 to 20 per cent of their shelf space to products supplied by black-run businesses.10 Purdie says this will benefit the retailers, particularly if consumers get behind the move.

“These are the trends investors need to understand, support and position for. Companies that don’t support them or change will suffer,” he explains.

Businesses can be an agent for change

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Culture shift 

Borhaug believes asset managers also need to engage with governments and regulators to create and implement legislation, not just on broader diversity matters but specifically on the issues faced by black people.

“We need to push governments to face up to their own challenges and recognise institutional racism. It may seem like a non-business issue, but we can tell governments we don’t want to live in a country where racial discrimination and police violence happen, and help support the organisations trying to tackle it,” says Borhaug.

You need to take your whole firm on a journey. That is where real leadership comes in

“We have a role to play, but can’t change the world on our own,” adds Baig. “When you are dealing with systemic institutional racism, it needs the strong hand of government. Industry bodies will also have to become more vocal and it is our responsibility to push them to take more action.”

The best-run firms will not wait for direction from governments before doing the right thing. Konotey-Ahulu notes companies with strong leadership will be proactively making the profound changes needed.

“You need to take your whole firm on a journey. That is where real leadership comes in, where you stand up and say: ‘This is the mountain we’re going to climb. I want you to come with us on this journey, and if you don’t want to come with us, you need to find another firm.’”

Why asset managers must get their own house in order

“The colour of my skin has already put up a mental barrier to what my aspirations are. I manage my expectations and my aspirations, telling myself this probably won’t happen,” says Aviva Investors’ Atoyebi. “Things are achievable in this industry. There are ways to network and to move up. But it’s hard to justify having such aspirations when I see nobody who looks like me in certain positions. I’m not even thirty, but I already know that.”

All companies need to set themselves clear pathways toward proportionate inclusion of ethnic minorities

The enduring presence of institutional racism and discrimination, particularly against black people, means all companies need to set themselves clear pathways toward proportionate inclusion of ethnic minorities. For asset managers, engaging with companies, as well as governments, industry bodies and NGOs, to effect change represents part of their stewardship responsibility. But for the demands to have teeth, the changes cannot be one-sided.

Redington’s Konotey-Ahulu says progress has been painfully slow, with little change in his 30 years in the industry. However, he now sees a real intention to change from financial organisations – something he has been advocating through the #TalkAboutBlack initiative that he co-founded11 – particularly through initiatives on intentional hiring and culture change.

“As often with progress, nothing happens for a long time and then things suddenly take off, similar to what we saw on climate change. I think this is what we are seeing on black minorities now,” he says.

Asset managers need to seize the opportunity and ensure the momentum is not lost. “If you don’t lead by example, you have no authority. We have to make sure people get an equal chance, and that people who don’t have that equal chance receive more support,” says Cumming.

Kinks in the hosepipe

The financial services industry is prone to all the “kinks in the hosepipe” Konotey-Ahulu described in his 2018 essay, ‘So, can we talk?’.

“[The kinks] run the length of the hosepipe: from very early childhood when, often, there is no-one telling black kids they can achieve something special in life […]; through to adolescence, when the dearth of high-achieving black role models means young black kids cannot look to the top of the judiciary or the medical profession, or the world of finance, or the arts, and think “That could be me one day!”; through to late teens when, if you do find yourself in higher education, no-one comes looking to hire you into their prestigious blue-chip organisations; through to the employment years, when the working corporate assumption often seems to be that you might, maybe, make it into middle management, but Partnership, Senior Management, the C-Suite, the Bench, the Board, the Chairman? – that’s just not going to happen.”12


No one telling black children they can achieve something special.

Parents cannot always invest time to supplement school education and set their children up for long-term success.


Dearth of high-achieving black role models to inspire young black children.

University / early adulthood

Blue-chip companies aren’t proactive in looking to hire black students.

Recruitment centres on STEM degrees from top universities.

A lack of connections in the corporate world during university and early adulthood.


Pervasive corporate assumption that black employees are unlikely to progress beyond middle management.

Corporate monoculture hinders recruitment and discourages applications.

Kinks in the hosepipe

What asset managers can do to help unkink the hosepipe

Dedicate permanent resources, both financial and human, to tackle racism at work, change practices, reach out to black communities outside the company, and maintain momentum.

Integrate diversity into the company’s business strategy in terms of product development, target audiences, suppliers, investment decisions and engagement with companies.

Childhood / adolescence

Go speak in schools. Tell black children about asset management, and that your company wants to attract people like them.

Work with dedicated NGOs to reach out to the right people, in the right way.

University / early adulthood

Redefine what good looks like in terms of diplomas and background.

Promote opportunities to the black community, e.g. through #100BlackInterns.

Review recruitment processes.


Set up ongoing firm-wide dialogue, training and awareness-raising. This should not be a one-off.

Ensure senior managers actively learn about the issues and take the whole firm on the journey.

Review promotion and retention processes, not just for BAME but for black employees specifically.

Collect data and set timelines and measurable targets. Measure and report on progress.

Use mentoring and sponsorship to help black employees build networks and open doors.

Courtesy of Dawid Konotey-Ahulu.

The industry presents two specific kinks that make it even harder for black people to join and thrive in the sector. First is the complexity of the business, which requires strong technical skills that are often only gained through a university degree in STEM subjects or economics. Black students are underrepresented in such degrees, and not encouraged often enough to pursue them.

According to research by the UK’s Social Mobility Commission, despite starting school with performance largely in line with national averages, black children are the ethnic group most likely to fail their Maths GCSE and among the least likely groups to achieve a good degree. The report attributes the relative underachievement to conscious and unconscious bias in the treatment of black pupils.13

These skills are also required further along the career path, meaning the pool of black candidates shrinks even further. The lack of black representation at the top of financial firms must be fixed, but it could be a slow process as the industry will have to do more around entry-level and junior recruitment, and then encourage career progression.14

There need to be more honest discussions within organisations about their commitment to ethnic diversity

This ties into the second issue, which is the barrier created by the prevalent – and perceived – corporate culture, of which class is a key element. Compared with white people, fewer black people in the UK have privileged upbringings and, to a large degree, people who succeed in financial services either come from upper-middle class backgrounds or have to give up part of their identity to fit in. In the UK, for instance, black children are the ethnic group most likely to grow up in poverty, with a quarter of students eligible for free school meals.15

This creates barriers in terms of recruitment, but also perception. Baig believes there is a misunderstanding across society of what asset management is and what its values are.

“Even before we get to issues about promotion and development, people of different backgrounds won’t even apply because of the idea they won’t fit in. It is monocultural versus multicultural,” he says.

Atoyebi believes there need to be more honest discussions within organisations about their commitment to ethnic diversity.

“What do they want to achieve? Are they just reacting to what is going on in the world or do they want to see change, do they want to see that diversity of thought, do they want to see different types of people? It is all well and good saying things like ‘we have to think about unconscious bias’, but it’s all the same types of people coming in, it’s all the same types of faces,” she says.

Soft skills, hard targets

While talking isn’t as tangible as changing policy, ‘soft’ areas like role modelling, awareness-raising and mentoring are crucial to showcase there is a place for people from diverse backgrounds.

Black representation on boards and in senior management needs to improve

However, timelines and measurable targets also need to be set: black representation on boards and in senior management needs to improve, business strategies must address the full array of customer types, recruitment and retention practices need updating and accurate data must be collected to measure progress.

But asset managers must also address the specific kinks of the industry in terms of educational and class biases. Training will be required, and awareness can be raised by encouraging people in the organisation to share their experiences.

Atoyebi thinks quotas can be helpful, if they are specific and measurable. “We need to be comfortable saying ‘black’ and put the mindset out there that it’s not simply a quota for the sake of it,” she says. “It is a quota to access qualified people who might bring different viewpoints and more diversity to the way the business is run and the way it thinks.”

Broaden the search

At an entry level, asset managers need to engage with less-privileged communities and challenge the preconception that not everyone can fit in.

“When people say they don’t know where all the black people are, what they really mean is they don’t know where all the Eton or Oxbridge-educated black people are. It’s not the same thing. Black people didn’t all go there,” adds Konotey-Ahulu.

He says there are black students who can offer cognitive diversity, determination and resilience. “They may not come in a nice, gift-wrapped box that says: ‘11 A-stars and a first-class degree in engineering from Oxford’, but they may nonetheless turn out to be the most successful employee you ever hired,” he says.

“The thing I keep going on about is the pipeline,” adds Atoyebi. “Where are you recruiting from? What does the stream look like for people already in the business? Which universities and schools are you looking at? Are you looking at school leavers? Are you looking at people who aren’t too sure about taking on a lot of student debt? Of course, people say it will just come out of your salary, but it’s still quite daunting for a lot of people from certain backgrounds.”

These are qualified people that don’t get a chance because they don’t relate that well to senior management

Borhaug points out one danger to this, which is the temptation to cut costs on outreach programmes and internships in a crisis. She says it is crucial to keep them, particularly at times like these.

“During COVID-19 we saw that as much as half of internship opportunities in the US were cut,” she says. “These programmes should be a permanent part of companies delivering the change we want, not a cost that gets cut when times get tough.”16

Although targets must be set and progress measured, other programmes such as mentoring and sponsorship will be vital. In part, this is because having privilege tends to come hand-in-hand with having a network – or at least being able to build one by dint of having a similar background – of senior people who can open doors.17 As these doors don’t typically exist for black or less-privileged employees, firms need to set up programmes to level the playing field.

“These are qualified people that don’t get a chance because they don’t relate that well to senior management. They don’t have their rugby banter, or they don’t talk about cricket, maybe, or something random like that. It’s the same as with gender,” says Atoyebi.

Fixing the supply kink

Beyond their own recruitment policies and culture, asset managers need to look at how they manage their investments, especially in the context of their fiduciary duty to clients. In real asset sectors such as real estate and infrastructure, shareholder engagement is not applicable, but there are opportunities to influence the supply chain.

We need to look in more depth at the diversity of the suppliers we deal with

“We deal with many suppliers, from construction companies to property service providers and power station operators. One of the areas we need to look at in more depth is diversity within those organisations. We can make a difference there,” says Mark Versey, chief executive officer at Aviva Investors.

The lack of existing data and the fact the issue is rarely raised with providers mean the first step is to gauge the current situation and the potential impact of changes to procurement policies. Second is reviewing procurement processes, asking suppliers to change their diversity policies where relevant, choosing those with good diversity credentials and supporting black businesses.

Harnessing diversity of thought

Improving diversity – of which better black representation must be a central part – is not just a question of doing the right thing; having diverse investment teams can improve decisions and outcomes.

Making better investment decisions will also mean analysing companies’ black representation and commitment to diversity

This is borne out by research that has found significant differences in people’s attitudes to risk and investing, meaning a more diverse group would likely make different decisions than a uniform team.18 Similarly, a 2014 article on price bubbles in financial markets by Sheen Levine et al found ethnically diverse markets were significantly more efficient than homogeneous ones.19

Making better investment decisions will also mean analysing companies’ black representation and commitment to diversity as part of research.

“It should be part and parcel of any investment discussion, in the same way as regulation, litigation, demographics and climate change. It is not going to change the process, but it will change the outcome,” explains Purdie.

The current momentum puts the onus on asset managers to change the composition of their teams and the way they make investment decisions.

Clients will demand change

Just as investors are likely to shun companies that do not adapt, clients and investment consultants will begin to take asset managers’ diversity practices and black representation into account when assessing them. Now that it is something that can be talked about, it is becoming a powerful lens to look at the social dimension of ESG.

We can’t “unkink the hosepipe” in a day, which is why asset managers need to stay the course

“In 12 to 18 months’ time, it is going to be a question. The manager research team will start asking asset managers about their ethnic mix, not only on BAME as a very broad category, but more specifically asking how many black senior employees they have. When that happens, it starts to turn the dial, because asset managers want to have good answers to those questions. If you are a smart asset manager you will figure that out,” says Konotey-Ahulu.

He acknowledges we can’t “unkink the hosepipe” in a day, however, which is precisely why asset managers need to stay the course. It took a tragedy to shake the industry out of its complacency; it is crucial the momentum is not lost now.


  1. ‘Power in the boardroom: Blacks in corporate governance’, Black Enterprise, October 2019
  2. ‘Power in the boardroom: Blacks in corporate governance’, Black Enterprise, October 2019
  3. Sir John Parker, ‘Ethnic diversity enriching business leadership: An update report from The Parker Review’, EY and National Equality Standard, February 5, 2020
  4. Dawid Konotey-Ahulu, ‘So, can we talk? #talkaboutblack’, LinkedIn, March 26, 2018
  5. ‘The scorecard report 2018: Race at work 2018’, Business in the Community, YouGov, Department for Business, Energy & Industrial Strategy, July 2018
  6. ‘Understanding diversity and inclusion in the investment management industry’, The Diversity Project, PwC, March 2018
  7. ‘The scorecard report 2018: Race at work 2018’, Business in the Community, YouGov and Department for Business, Energy & Industrial Strategy, July 2018
  8. ‘Best of Today: Facebook must "develop a conscience"’, BBC, June 30, 2020
  9. Kari Paul, ‘Facebook policy changes fail to quell advertiser revolt as Coca-Cola pulls ads’, The Guardian, June 27, 2020
  10. Kathleen Hou, ‘Sephora is making a big move to support Black businesses’, The Cut, June 11, 2020
  11. Dawid Konotey-Ahulu, ‘So, can we talk? #talkaboutblack’, LinkedIn, March 26, 2018
  12. Dawid Konotey-Ahulu, ‘So, can we talk? #talkaboutblack’, LinkedIn, March 26, 2018
  13. Bart Shaw, Loic Menzies, Eleanor Bernardes, Sam Baars, Philip Nye, Rebecca Allen, 'Ethnicity, gender and social mobility’, Social Mobility Commission, December 28, 2016
  14. Gavin Lewis, ‘#ActionNotWords’ video, Diversity Project, 2020
  15. Bart Shaw, Loic Menzies, Eleanor Bernardes, Sam Baars, Philip Nye, Rebecca Allen, 'Ethnicity, gender and social mobility’, Social Mobility Commission, December 28, 2016
  16. Abigail Hess, ‘As much as half of internship opportunities have been cut due to coronavirus’, CNBC, April 30, 2020
  17. Sam Friedman and Daniel Laurison, ‘The class ceiling: Why it pays to be privileged’, Bristol University Press, January 6, 2020
  18. Trond Svela Sand & Anders McDonald Sookermany, ‘Risk-taking attitudes and behaviors in the Norwegian population: the influence of personality and background factors’, Journal of Risk Research, 2020, DOI: 10.1080/13669877.2020.1750455
  19. Sheen Levine, Evan Apfelbaum, Mark Bernard, Valerie Bartelt, Edward Zajac, David Stark, ‘Ethnic diversity deflates price bubbles’, PNAS, December 30, 2014, 111 (52) 18524-18529

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The name “Aviva Investors” as used in this material refers to the global organization of affiliated asset management businesses operating under the Aviva Investors name. Each Aviva investors’ affiliate is a subsidiary of Aviva plc, a publicly- traded multi-national financial services company headquartered in the United Kingdom.

Aviva Investors Canada, Inc. (“AIC”) is located in Toronto and is based within the North American region of the global organization of affiliated asset management businesses operating under the Aviva Investors name. AIC is registered with the Ontario Securities Commission as a commodity trading manager, exempt market dealer, portfolio manager and investment fund manager. AIC is also registered as an exempt market dealer and portfolio manager in each province of Canada and may also be registered as an investment fund manager in certain other applicable provinces.

Aviva Investors Americas LLC is a federally registered investment advisor with the U.S. Securities and Exchange Commission. Aviva Investors Americas is also a commodity trading advisor (“CTA”) registered with the Commodity Futures Trading Commission (“CFTC”) and is a member of the National Futures Association (“NFA”). AIA’s Form ADV Part 2A, which provides background information about the firm and its business practices, is available upon written request to: Compliance Department, 225 West Wacker Drive, Suite 2250, Chicago, IL 60606.