The Wiltshire Pension Fund Committee met on 20 November 2025 to discuss responsible investment, compliance with MiFID II¹, and the date of the next meeting. The committee was also scheduled to receive training on the Stewardship Code². Part of the meeting was scheduled to be held with the public excluded, in order to discuss the Scheme's Investment Strategy review, the Fund's quarterly investment performance, and changes to the Pooling Arrangements.

Responsible Investment Update

The Investment and Accounting Team Lead was scheduled to present a report on the Fund's quarterly responsible investment performance.

The report included an update on the Responsible Investment Plan 2025/26, including:

• Climate scenario modelling and carbon foot printing
• Development of options for a Local Investment Portfolio
• Social and Affordable housing impact report
• Stewardship Report
• Climate scenario modelling training
• Review and published updated RI Policy
• Implement Strategic Asset Allocation (SAA) review ensuring Responsible Investment is embedded in allocation process
• Support development of Nature Portfolio by Brunel³
• Climate, Nature and CLOPS impact report
• Set out engagement approach for top 10 emitters
• Report on how effectively Responsible Investment Objectives can be met following consultation outcomes
• Investigate climate targets for PM portfolios (PE & PD)
• Nature Impact: Assess investments against the NA100 benchmark, outline top holdings in high impact sectors
• Review progress against climate targets in 91 EMMA portfolio
• Provide relevant content for Pension Awareness Week (PAW)
• Investigate setting Fund Biodiversity reporting targets
• Review progress against 2025 climate targets and pathway to meet 2030 targets
• Assess investment holdings of weapons companies.
• Fund to attend the LAPFF⁴ annual planning meeting
• Ongoing relevant site visits (Property, Affordable Housing, Wessex Gardens, World Fund)
• Hold Brunel and other investment managers to account on our priorities
• Voting reports
• Holdings report
• Case studies on our Social Factors (x4)
• Highlight relevant partnership engagement work (LAPFF, IIGCC⁵)

The report also included updates on:

• The Climate and Nature Report, which was scheduled to be published on the Funds website on 20th November.
• Site visits to investments in the UK, including a District Heating System in Battersea, and upcoming visits to affordable housing sites in Chippenham and Aldershot, and a local site visit to understand more about Natural Capital.
• Voting rights, with quarterly reports published on the Wiltshire Pension Fund website.
• A review of weapons companies.

As a member of LAPFF, the Fund benefits from collaborative engagement on corporate governance and responsible investment issues. LAPFF engaged with luxury goods companies, including LVMH (Luis Vuitton Moët Hennessy), where the Fund holds £4.5 million. This engagement was driven by reports of labour abuses involving a third-tier subcontractor in the Italian supply chain of Loro Piana, a brand owned by LVMH.

Investments in weapons companies

The report included a review of the Fund's investments in Aerospace and Defence (A&D) holdings. A&D holdings equate to 0.47% of total holdings as at Q2 2025.

The report stated that the Fund already relies on exclusions for companies involved in controversial weapons or those breaching UN human rights principles, such as Lockheed Martin and RTX.

The report also stated that legally, investments in A&D companies supplying Israel are permissible under UK law.

The report included a table breaking down the Fund's investments under the Aerospace & Defence (A&D) industry classification:

The report also included a table breaking down the fund's market share holdings in Aerospace and Defence Sector in Q2 2025 and their link to Israel-Palestine conflict. As of Q2 2025, 0.37% of companies in the Aerospace and Defence sector held by the fund have been identified as have a link to the conflict:

The report noted that quantifying corporate involvement in the Israel-Palestine conflict is challenging due to the complexity of defence supply chains, varying levels of transparency, and indirect partnerships.

The report also included a table of Q2 holdings in companies identified by the United Nations as being complicit in activities related to illegal Israeli settlements in the occupied Palestinian territory:

MiFID II Compliance

The Investment and Accounting Team Lead was scheduled to present an update regarding ongoing assessment of compliance with MiFID II. The committee was asked to confirm that the fund should retain opted up for professional investor status.

Local and public authorities were reclassified as retail investors from 3 January 2018. Such a reclassification would severely limit the investment opportunities available to the Fund, preventing it from implementing the investment strategy. By opting for professional status the fund also loses some of the protections granted to retail investors.

The committee was asked to assess whether they collectively undertake the necessary continuous training, and receive suitable support to ensure they remain competent to perform the duties and responsibilities associated with investment decision-making.

Exclusion of the Public

The agenda included a resolution to exclude the public from the meeting for the business specified in Item Numbers 13 – 16 because it is likely that if members of the public were present there would be disclosure to them of exempt information as defined in paragraphs 1 & 3 of Part I of Schedule 12A to the Local Government Act 1972⁶ and the public interest in withholding the information outweighs the public interest in disclosing the information to the public. These items were:

• Part II Minutes of Previous Meeting(s)
• SAA Review and Proposal
• Investment Quarterly Update
• Investment Pooling Update