Impax Asset Management : Global Order Execution Policy

Global Order Execution Policy Disclosure

Date: October 2020

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1. Introduction

The purpose of this document is to provide clients of Impax with information about the Impax's best execution policy and to seek their consent to that policy.

Impax Asset Management Group plc, Impax Asset Management Limited, Impax Asset Management (AIFM) Ltd, Impax Asset Management LLC, Impax Asset Management (Hong Kong) Ltd and Impax Asset Management (Ireland) Ltd (collectively, "Impax" or the "Firm"), and Pax World Funds Series Trust I and Pax World Funds Series Trust III (the "Pax World Funds"), have developed a global best execution framework.

In this policy the UCITS, segregated accounts and AIFs are referred to as "Clients". The Firm is a specialist asset manager and as such liquidity seeking is often the priority.

Impax Asset Management LLC ("Impax US" or "NH") and Impax Asset Management Limited ("Impax UK" or "LN") execute all equity trades on a centralised dealing desk via the Impax UK Legal Entity Identifier ("LEI").Impax NH trades fixed securities under its own LEI.

This document constitutes the Firm's Best Execution policy and procedures (the "Policy"). It sets out the policy and procedures of the Firm that have been established and implemented to ensure sound, transparent and comprehensive execution processes are followed and specifies the controls and safeguards that are in place. This policy applies to all group employees globally. Impax complies with requirements in all local jurisdictions.

The Policy applies when executing client orders directly on an Execution Venue and transmitting or placing orders with other entities for execution. The Firm is required to take all sufficient steps to obtain consistently over time (and not in relation to every single order) the best possible result when executing client orders, (collectively referred to as ("execution") throughout this policy.

The Firm conducts its business in accordance with all applicable laws and regulations, including the requirements of Conduct of Business Rules ("COBS") 11.2A "Best Execution" of the FCA Handbook.

The Firm must act in the best interests of its clients when executing decisions to deal, taking into account a number of execution factors and criteria which are discussed in detail below.

The Firm's senior management is responsible for ensuring that robust business practices are operating in all its trading activities to deliver Best Execution on a consistent basis and for promoting a culture that proactively identifies and manages conflicts of interest. The Firm's senior management are also responsible for the on- going review and monitoring of this Policy, to ensure that it remains robust and fit for purpose, taking into account, amongst other things, changes to market structures and execution practices and development of new products.

2. Order Handling

The Firm only executes orders indirectly via brokers' infrastructure, circuit breakers and controls. The Firm does not connect directly to an exchange. All orders are placed with a broker for execution. The majority of orders are traded electronically via a broker algorithm ("algo"). However, in certain circumstances, orders may be traded "high touch", defined as directly with a sales trader over the telephone to a broker. Subject to local regulatory requirements Impax may aggregate orders with one or more other clients. Impax will fairly allocate aggregated orders and transactions over time.

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3. Execution Factors

When executing orders, the Firm will take all sufficient steps to achieve Best Execution, subject to and taking into account, any specific instructions from the client, the nature of such orders, the priorities its clients' place upon it in filling those orders and the nature of the markets and products in question.

In order to deliver Best Execution, the Firm uses its knowledge, experience and judgement to execute trades on behalf of its clients taking into consideration a number of execution factors including:

• The price that the order can be executed at;
• The costs of execution of the transaction to the client;
• The speed of execution of the transaction;
• The size and nature of the order; and
• The likelihood of achieving execution and settlement;
• Any other consideration relevant to the execution of the specific order (the "Execution Factors").

4. Execution Criteria

The Firm is required to determine the relative importance of the Execution Factors for its clients by taking into account the following criteria:

• The characteristics of the client, including the categorisation of the client;
• The characteristics and the nature of the client order;
• The characteristics of the financial instruments that are the subject of that order; and
• The characteristics of the execution venues/brokers to which that order can be directed (the "Execution Criteria").

In considering the Execution Criteria and the importance of the Execution Factors, the Firm also takes into account the client's understanding and experience of the market in question, the client's dealing profile, the nature of the dealing service the client requires and the specific and general instructions given to the Firm by the client, which may prioritise how the Firm fills client orders.

5. Brokers

The Firm will primarily select the broker that, in the Firm's judgment, is the most appropriate, taking into account the Execution Factors and Execution Criteria. The Firm will also consider the market coverage and execution advisory that the execution broker can provide.

When determining the approach to achieve Best Execution the trader must determine which broker to use (where more than one is available for a particular financial instrument). The Firm will consider the cost and commission implications of each method, where there are competing options.

The Firm has identified, outlined in ANNEX A attached, those brokers with which it most regularly seeks to place orders and which the Firm believes offer the best prospects for affording its clients Best Execution.

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5.1 Selection of Brokers

The Firm has a thorough selection process with respect to the brokers that it transacts with, which is designed to identify those brokers which consistently provide a high-quality execution service, taking account of the relevant Execution Factors and Execution Criteria. Orders may only be placed with brokers which have been approved by the Firm following its internal selection process.

The Firm is not permitted to place orders with a broker that is not already approved by the firm.

5.2 Cross Trades

Impax may cross between funds this crossing provides a mutually beneficial opportunity for clients and only if it is done in accordance with the Cross Trade Policy and Procedures.

5.3 OTC Products

For the execution of trades in illiquid financial instruments, brokers who trade in the same securities or securities with similar characteristics may be prioritised. When executing trades with a Systematic Internaliser (SI), these trades may be flagged as OTC. However, the SI is to provide pre-trade transparency, which meets Impax's obligation to undertake systematic checks to ensure the price quoted is "fair".

6. Detailed Requirements for Each Financial Instrument Class Traded

6.1 Introduction

For each class of financial instruments traded, the Firm has defined the key Execution Factors that will be taken into account when placing orders for execution, in order to choose the counterparty that best suits its requirements.

The principles described in this Policy do not restrict the Firm to act otherwise, where it considers that to follow the Policy may result in an order not being executed in a way that the best possible result is obtained for the client.

In case of extreme circumstances, such as disruption of the execution system, the Firm may not be able to execute an order in accordance with this Policy. In such exceptional circumstances, the Firm will endeavour to execute client orders in the most advantageous way for its client under the prevailing circumstances.

If only one place of execution exists, Best Execution is realised when executing the order in that execution venue. The Firm will be able to demonstrate that only one place of execution exists. Currently Impax only trades equities. As such, any limitations or conflicts on the selection of execution venues when also trading Securities Financing Transactions (SFTs) do not apply.

6.2 Equity Trading

A method of order evaluation is used to place orders into types, based on their characteristics such as difficulty, urgency, conviction, timescale, size or price constraint. Understanding the rationale

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