| Organisational Overview | |||
| 1. What were your organisation's total assets under management as of 31 December 2007 (in millions)? | 114212 | ||
| Please select currency | Euro (EUR) | ||
| 1a. If 'Other' was selected, please specify the other currency here | |||
| 2. What category would best describe your organisation? | |||
| 3. What proportion (in %) of your fund is defined benefit and what proportion (in %) is defined contribution? (please only answer this question if you answered “Pension or superannuation or retirement or provident fund or plan” to Q2) | |||
| Defined benefit | |||
| Defined contribution | |||
| 4. Please provide an overview of your asset mix as of 31 December 2007 (in %): | |||
| Listed equity (developed market, active) | 83.6 | ||
| Listed equity (developed market, passive) | 0 | ||
| Listed equity (emerging market, active) | 3.9 | ||
| Listed equity (emerging market, passive) | 0 | ||
| Fixed income - developed markets | 1.5 | ||
| Fixed income - emerging markets | 0 | ||
| Real estate or property | 0 | ||
| Private equity | 0 | ||
| Hedge fund | 0 | ||
| Infrastructure | 0 | ||
| Currency | 0 | ||
| Commodities | 0 | ||
| Cash | 0 | ||
| Other (Please specify): Balanced, multi-assets, money markets, passive | 11 | ||
| Balanced, multi-assets, money markets, passive | |||
| 5. Please indicate what percentage of your assets are managed internally and what percentage are managed externally (in %): | |||
| Listed equity (developed market, active) | 100 | 0 | |
| Listed equity (developed market, passive) | 0 | 0 | |
| Listed equity (emerging market, active) | 100 | 0 | |
| Listed equity (emerging market, passive) | 0 | 0 | |
| Fixed income - developed markets | 0 | 100 | |
| Fixed income - emerging markets | 0 | 0 | |
| Real estate or property | 0 | 0 | |
| Private equity | 0 | 0 | |
| Hedge fund | 0 | 0 | |
| Infrastructure | 0 | 0 | |
| Currency | 0 | 0 | |
| Commodities | 0 | 0 | |
| Cash | 0 | 0 | |
| Other (Please specify): balanced, multi-assets, money markets, passive | 100 | 0 | |
| balanced, multi-assets, money markets, passive | |||
| 6. Please provide the following contact details for your main PRI contact: | |||
| URL for webpage outlining the specific services and products your organisation has to assist signatories in fulfilling their commitments to the Principles | http://www.rcm.co.uk/solutions/09_sustainability.html | ||
| Principle 1 | |||
| 7. Do you have a formal investment policy statement that makes specific reference to the integration of responsible investment (RI) or environmental, social and governance (ESG) issues within investment decision making and ownership practices? | |||
| 8. Do you have a statement that makes specific reference to the integration of responsible investment (RI) or environmental, social and governance (ESG) issues within investment decision making and ownership practices? | Yes, it is integrated into a broader statement and there is an independent RI/ESG statement | ||
| 9. In what year were RI/ESG issues first formally addressed in a policy statement (integrated or independent)? | 2000 | ||
| 10. Has your statement that makes specific reference to the integration of RI or ESG issues been disclosed publicly? | Yes | ||
| 11. Please indicate how this statement that makes specific reference to the integration of RI or ESG issues can be obtained (a URL would be sufficient): | http://www.rcm.co.uk/download/9901_RCM_and_its_Sustainable_Investment_Philosophy_HP15081.pdf | ||
| 12. For what percentage of your internal assets under management do you integrate RI/ESG issues into your internal investment decision-making processes? (in %) | |||
| Listed equity (developed market, active) | 2.5 | ||
| Listed equity (developed market, passive) | |||
| Listed equity (emerging market, active) | 0 | ||
| Listed equity (emerging market, passive) | |||
| Fixed income - developed markets | |||
| Fixed income - emerging markets | |||
| Real estate or property | |||
| Private equity | |||
| Hedge fund | |||
| Infrastructure | |||
| Currency | |||
| Commodities | |||
| Cash | |||
| {inst1} | 0 | ||
| 13. To what extent have you integrated RI/ESG issues into your internal investment decision-making processes? | |||
| Listed equity (developed market, active) | To a moderate extent | ||
| Listed equity (developed market, passive) | Not at all | ||
| Listed equity (emerging market, active) | Not at all | ||
| 14. For what percentage of your external assets under management are RI/ESG issues integrated into the investment decision-making processes of your external investment managers? (in %) | |||
| Listed equity (developed market, active) | |||
| Listed equity (developed market, passive) | |||
| Listed equity (emerging market, active) | |||
| Listed equity (emerging market, passive) | |||
| Fixed income - developed markets | 0 | ||
| Fixed income - emerging markets | |||
| Real estate or property | |||
| Private equity | |||
| Hedge fund | |||
| Infrastructure | |||
| Currency | |||
| Commodities | |||
| Cash | |||
| {inst} | |||
| 15. To what extent have RI/ESG issues been integrated into the investment decision-making processes of your external investment managers? | |||
| Listed equity (developed market, active) | Not at all | ||
| 16. What proportion of your assets involve screening out or excluding stocks or sectors based on ethical (rather than long-term financial) criteria? (in %) | 0.7 | ||
| 17. Do you have any staff dedicated to RI/ESG issue analysis and/or implementation? | |||
| Investment analyst | 0 | 0 | |
| Research analyst | 4 | 0 | |
| RI/ESG issue policy advisor | 0 | 0 | |
| (proxy) Voting specialist | 1 | 0 | |
| Engagement specialist | 0 | 0 | |
| Portfolio manager | 0 | 1 | |
| Other (Please specify): Specialist environmental technology analyst and portfolio manager | 1 | 0 | |
| Specialist environmental technology analyst and portfolio manager | |||
| 18. Which Board committee or other executive body has overall responsibility for RI/ESG issues? | Andreas Utermann, Global CIO at RCM and Chair of the Global Policy Council has overall responsibility for Sustainability Research/Responsible Investment | ||
| 19. Do you assess the capabilities of internal investment staff to incorporate RI/ESG issues? | Yes | ||
| 20. Do you assess the capabilities of external investment managers to incorporate RI/ESG issues? | No | ||
| 21. Approximately what percentage of your internal non-ESG-specialist investment management staff received RI/ESG training in 2007? (in %) | 100 | ||
| 22. What forms of RI/ESG training or awareness raising have been invested in, encouraged or provided for internal staff (investment and other)? | Informal internal training,Regular briefings on key issues | ||
| 23. Did you support the development of nonproprietary RI/ESG issue-related tools, metrics, analysis or academic research in 2007? | To a large extent | ||
| 24. Please indicate how the results of nonproprietary RI/ESG issue-related tools, metrics, analysis or academic research development you supported can be obtained if they have been disclosed publicly (a URL would be sufficient): | http://www.dvfa.de/die_dvfa/kommissionen/non_financials/dok/35683.php http://www.unepfi.org/fileadmin/documents/infocus.pdf http://www.unepfi.org/fileadmin/documents/Demystifying_Responsible_Investment_Performance_01.pdf | ||
| 25. Have you advocated/supported/ encouraged/participated in RI/ESG issue-related industry-wide training for investment professionals during 2007? | Spoke at or attended conferences,Had dialogue or exchanges with peers,Instructed at universities or colleges | ||
| 26. What was your most significant achievement in 2007 in relation to your implementation of Principle 1? | Co-chairing the DVFA Non-Financials Committee. Working to define a set of Key Performance Indicators for corporate reporting of non-financial performance data in traditional corporate reports, focussing on ESG issues. Committee has circulated a set of 25 KPIs to a wider audience of mainstream investment professionals in Europe in order to survey the perception of those KPIs. The Committee is currently gathering feedback before publishing the KPIs as "guidelines" for companies, to demonstrate what non-financial information mainstream investors find useful for valuation purposes. Additionally, the DVFA will try to identify ways to internalise this information into financial models and will educate members accordingly. | ||
| 27. What was your biggest barrier in 2007 with relation to your implementation of Principle 1? | It can be difficult to gain widespread support for full ESG integration if existing and/or potential clients are not asking for it. | ||
| 28. Please add any overall comments and clarifications related to Principle 1 here. | Enter text response here. | ||
| Principle 2 | |||
| 29. To what extent did you employ the following approaches in your 2007 active ownership strategy for listed equities? | |||
| (Proxy) voting | To a moderate extent | ||
| Direct engagement conducted privately | To a large extent | ||
| Direct engagement conducted publicly | Not applicable | ||
| Collaborative engagement | Not applicable | ||
| Filing shareholder resolutions | Not applicable | ||
| Co-filing shareholder resolutions | Not applicable | ||
| Other (Please specify): | No Answer | ||
| 30. To what extent did you employ the following approaches in your 2007 active ownership strategy for all asset classes other than listed equity? | |||
| (Proxy) voting | Not at all | ||
| Direct engagement conducted privately | Not at all | ||
| Direct engagement conducted publicly | Not at all | ||
| Collaborative engagement | Not at all | ||
| Other (Please specify): | No Answer | ||
| 31. Do you have a (proxy) voting policy? | Yes - disclosed publicly | ||
| 32. To what extent does your (proxy) voting policy direct action on ESG issues? For each issue, please indicate the extent of direction. | |||
| Environmental | To a small extent | ||
| Social | To a small extent | ||
| Governance | To a large extent | ||
| 33. Does your (proxy) voting policy apply to all voting regions (where possible)? | Yes | ||
| 34. Please indicate how your (proxy) voting policy can be obtained (a URL would be sufficient): | http://www.rcm.co.uk/about_rcm/05_corporate_governance.html | ||
| 35. Do you ensure that voting is done in accordance with your (proxy) voting policy? | Yes for all | ||
| 36. What percentage of total votes cast were against management? (in %) | 6.2 | ||
| 37. What percentage of shareholder resolutions relating to environmental, social or governance issues was supported? (in %) | |||
| Environmental | 0 | ||
| Social | 12 | ||
| Governance | 100 | ||
| 38. Do you conduct (proxy) voting on behalf of your clients? | Yes - According to our own policy or client-specific policies | ||
| 39. How many shareholder resolutions related to RI/ESG issues did you participate in during 2007? | |||
| As lead filer | |||
| As co-filer | |||
| Planning to be lead filer in 2008 | |||
| Planning to be co-filer in 2008 | |||
| 40. How were portfolio companies engaged with in 2007? Please check all that apply. | Internal staff engaged portfolio companies directly | ||
| 41. Do you systematically bring RI/ESG issue-related engagement opportunities to your clients? | Not required | ||
| 42. Do you systematically ask your external investment managers to bring RI/ESG issue-related engagement opportunities to you? | |||
| 43. How many portfolio companies did you engage directly/were engaged on your behalf on ESG issues in 2007? | |||
| Environmental | 0 | 0 | 57 |
| Social | 0 | 0 | 57 |
| Governance | 0 | 0 | 57 |
| 44. What RI/ESG-related issues were addressed in your shareowner engagement initiatives? Please check all that apply. | Activities in conflict zones,Benefits and compensation,Bribery/corruption,Climate change,Distribution of fair trade products,Environment,Governance,HIV/AIDS,Health,Health and safety,Human rights,Labour issues,Nanotechnology / novel technology,Other (please specify): 'resource consumption, opportunities derived from environmental and social trends, response to regulation, research and development relating to environmental and social issues/trends/concerns, customer protection, supply chain management' | ||
| 45. How were RI/ESG issue-related engagement targets and topics identified? Please check all that apply. | Sector exposure,Risk profile,Ad hoc/reactive,Other (please specify): 'New business opportunities derived from environmental and social trends' | ||
| 46. Do you set RI/ESG issue-related engagement objectives and attempt to evaluate success? | To a small extent | ||
| 47. Have you sought evidence relating to the effectiveness of your active ownership strategy? Please check all that apply. | Improved disclosure | ||
| 48. What was your most significant achievement in 2007 in relation to your implementation of Principle 2? | Enter text response here. | ||
| 49. What was your biggest barrier in 2007 with relation to your implementation of Principle 2? | Enter text response here. | ||
| 50. Please add any overall comments and clarifications related to Principle 2 here. | RCM does not have a formal corporate engagement strategy. However, as a long-term, research-driven, stock-picking asset manager, an in-depth knowledge of corporate strategy and the inner workings of the business, obtained in part via regular meetings with company management, is essential. These meetings focus on a range of issues including environmental, social and governance risks and opportunities. Such corporate dialogue also provides the opportunity for us to express our views on the importance of good ESG management, to highlight areas of company performance that we believe may present a risk to shareholder value, to exchange views on how ESG performance should be reported to shareholders, and to provide feedback on how a company is performing relative to its peers. In this way, RCM hopes and believes it is encouraging companies to be more transparent and take better account of ESG risks and opportunities. | ||
| Principle 3 | |||
| 51. Have you asked that investee companies (or other investment entities) produce standardized reporting on their RI/ESG issue policies, practices or performance (within annual financial reports or other formats)? | To a small extent | ||
| 52. What format of standardized reporting on RI/ESG issue policies, practices or performance have you requested? | Standalone corporate social responsibility or sustainability reporting,Global Reporting Initiative (GRI) | ||
| 53. Have you provided feedback to investee companies (or other investment entities) on their reporting on RI/ESG issues? | To a moderate extent | ||
| 54. Have you sought information from companies regarding their adoption of/adherence to norms, standards, codes of conduct or international initiatives related to RI/ESG issues? | |||
| Adoption | To a small extent | ||
| Adherence | To a small extent | ||
| 55. Which norms, standards, codes of conduct or international initiatives related to RI/ESG issues have you sought information about from companies, with regard to their adoption of/adherence to? | UN Global Compact,Equator Principles,International Labour Organization standards,Universal Declaration of Human Rights | ||
| 56. What was your most significant achievement in 2007 in relation to your implementation of Principle 3? | Enter text response here. | ||
| 57. What was your biggest barrier in 2007 with relation to your implementation of Principle 3? | Enter text response here. | ||
| 58. Please add any overall comments and clarifications related to Principle 3 here. | Enter text response here. | ||
| Principle 4 | |||
| 59. Are you considering RI/ESG requirements when searching for and selecting the following? | |||
| External investment manager | No | ||
| Investment consultant | Not applicable | ||
| Proxy voting | Yes | ||
| Engagement overlay | Not applicable | ||
| Investment research | Yes | ||
| Internal operations (for example, purchasing, travel, office space etc.) | Yes | ||
| Other (Please specify): | Not applicable | ||
| 60. Have you linked the following to performance on RI/ESG issues? | |||
| Investment monitoring | No | ||
| Incentive structure (internal investments) | No | ||
| Incentive structure (external investments) | No | ||
| Contractual relationships with external investment managers | No | ||
| 61. Are the default pension funds or retirement plans offered to your employees also signatories to the PRI? | Yes | ||
| 62. To what extent do you encourage your service providers to become PRI signatories? | To a small extent | ||
| 63. To what extent do you encourage your clients to become PRI signatories? | To a small extent | ||
| 64. To what extent do you encourage peer organisations to become PRI signatories? | To a small extent | ||
| 65. Do you have evidence that you have played a role in the improved integration of RI/ESG issues by external investment managers? | Not at all | ||
| 66. Does your broker evaluation process include an ESG component or do you have a budget to pay cash for ESG broker research? | Yes | ||
| 67. Have you revisited any relationships with service providers in light of RI/ESG issue-related capabilities? | Yes | ||
| 68. Have you engaged in dialogue, lobbying or initiatives pertaining to government policy and/or industry regulations (for example, stock exchanges, accounting standards) related to RI/ESG issues in 2007? | To a large extent | ||
| 69. What was your most significant achievement in 2007 in relation to your implementation of Principle 4? | Enter text response here. | ||
| 70. What was your biggest barrier in 2007 with relation to your implementation of Principle 4? | Enter text response here. | ||
| 71. Please add any overall comments and clarifications related to Principle 4 here. | Enter text response here. | ||
| Principle 5 | |||
| 72. Did you use the PRI Engagement Clearinghouse in 2007? | No | ||
| 73. Did your use of the clearinghouse result in subsequent action or collaboration with other signatories? | No Answer | ||
| 74. Please elaborate on how the PRI Engagement Clearinghouse could be made more useful: | Enter text response here. | ||
| 75. To what extent do you participate in the following RI/ESG issue-related collaborative engagement initiatives and/or industry associations? For those not listed, please use the "other" field: | Carbon Disclosure Project,Enhanced Analytics Initiative (full member) (EAI),Regional social investment organisation (for example SIF or UKSIF),United Nations Environmental Program Finance Initiative (UNEP FI),Other (please specify): '' | ||
| 77. What was your most significant achievement in 2007 in relation to your implementation of Principle 5? | Enter text response here. | ||
| 78. What was your biggest barrier in 2007 with relation to your implementation of Principle 5? | Enter text response here. | ||
| 79. Please add any overall comments and clarifications related to Principle 5 here. | Enter text response here. | ||
| Principle 6 | |||
| 80. Have you disclosed how RI/ESG issues are integrated into your investment processes? | Yes - to clients or beneficiaries | ||
| 81. Please indicated how this disclosure of how RI/ESG issues are integrated into your investment processes can be obtained (a URL would be sufficient): | Not publicly available. | ||
| 82. To what extent do you disclose your annual (proxy) voting record? | Disclose votes only | ||
| 83. Please indicated how your (proxy) voting record can be obtained (a URL would be sufficient): | http://www.allianzglobalinvestors.de/ueber_uns/treuhaenderfunktion/images/zusammenfassung_2007_en.pdf | ||
| 84. Do you systematically report (privately and/or publicly) on your RI/ESG issue-related engagement activities, results and progress? | To a small extent | ||
| 85. Please indicate how your reporting on RI/ESG issue-related engagement activities, results and progress can be obtained (if it is publicly available, a URL would be sufficient): | Not yet publicly available. Outlined in client reports on a 4-month basis. We do have plans to publish these reports on-line. | ||
| 86. Did you communicate on RI/ESG issues and the PRI to beneficiaries or plan participants in 2007? | |||
| 87. Please indicate how your communication on RI/ESG issues and the PRI to beneficiaries or plan participants can be obtained (if it is publicly available, a URL would be sufficient): | |||
| 88. Are you undertaking any additional efforts to raise awareness of the PRI and RI/ESG issues amongst stakeholders? | Planning to in 2008 | ||
| 89. What evidence do you have of the impact on external investment manager practices? Please check those that apply. | Not applicable | ||
| 90. Have you sought to determine what impact your overall RI/ESG issue-related efforts (voting and engagement, investment decision making, disclosure, etc.) have had on corporate behavior or performance? | To a small extent | ||
| 91. Have you sought to determine what impact your RI/ESG issue-related approach has had on the performance of your portfolio? | To a small extent | ||
| 92. Have you sought to determine what impact your RI/ESG issue-related efforts, requests and guidance have had on the consideration of RI/ESG issues by your external service providers excluding external investment managers (for example: research providers, consultants, etc.)? | To a large extent | ||
| 93. Do you report on progress and/or achievements relating to the PRI or RI, and how would you like to publish your response to this assessment? | Please automatically publish our responses to the reporting and assessment tool in full on the PRI website | ||
| 94. What was your most significant achievement in 2007 in relation to your implementation of Principle 6? | Enter text response here. | ||
| 95. What was your biggest barrier in 2007 with relation to your implementation of Principle 6? | Enter text response here. | ||
| 96. Please add any overall comments and clarifications related to Principle 6 here. | Enter text response here. | ||
| Emerging Markets | |||
| 97. To what extent have you actively thought about how to integrate RI/ESG issues within investment decision making and ownership practices with regards to emerging markets investments? | To a small extent | ||
| 98. Please describe your activities with regards to integrating RI/ESG issues within investment decision making and ownership practices with regards to emerging markets investments. | Our activities to date have focussed on extending our universe of Sustainability Research coverage to stocks in emerging markets, using existing internal processes, and encouraging our external research providers (Innovest and Vigeo) to consider extending their coverage to these markets. The Sustainability Research team at RCM regularly shares research on ESG issues in emerging economies with the rest of the investment decision-making team. | ||
| 99. To what extent do you believe the integration of ESG issues in emerging markets is as relevant as the integration of ESG issues in other markets? | To a greater extent | ||
| 100. To what extent did you employ the following approaches in your 2007 active ownership strategy in emerging markets? | |||
| (Proxy) voting | Not at all | ||
| Direct engagement conducted privately | Not at all | ||
| Direct engagement conducted publicly | Not at all | ||
| Collaborative engagement | Not at all | ||
| Filing shareholder resolutions | Not at all | ||
| Co-filing shareholder resolutions | Not at all | ||
| Other (Please specify): not applicable | Not Applicable | ||
| 101. To what extent have you developed a comprehensive RI/ESG engagement capability regarding business activities in emerging markets? | Not at all | ||
| 102. Please list the three most often addressed RI/ESG-related issues in your shareholder engagement initiatives in emerging markets? | |||
| 1. | |||
| 2. | |||
| 3. | |||
| 103. Have you sought information from companies regarding their adoption of/adherence to norms, standards, codes of conduct or international initiatives related to RI/ESG issues in emerging markets? | |||
| Adoption | To a small extent | ||
| Adherence | To a small extent | ||
| 104. Do you take RI/ESG considerations into account when selecting and approving emerging markets external investment managers? | Not at all | ||
| 105. Do your consultants factor RI/ESG issues into their short listing of emerging markets external investment managers? | Not at all | ||
| 106. Do you have evidence that you have played a role in the improved integration of RI/ESG issues by external investment managers investing in emerging markets? | Not at all | ||
| 107. To what extent have you worked together with other investors to improve the effectiveness of implementing the PRI in emerging markets? | Not at all | ||
| 108. Are you undertaking any additional efforts to raise awareness of RI/ESG issues in emerging markets? | To a small extent | ||
| 109. Have you sought to determine what impact your RI/ESG issue-related efforts (voting and engagement, investment decision making, disclosure, etc.) have had on corporate behaviour or performance in emerging markets? | To a small extent | ||
| 110. Please add any overall comments and clarifications related to the PRI in emerging markets here. | No Answer | ||
| 111. What is your top PRI-related goal/priority for emerging markets in 2008? | To continue to analyse the environmental, social and governance risks and opportunities in these markets, to engage with companies who might be exposed to these risks and opportunities, both directly and indirectly, in order to understand their strategy (if necessary and where possible, by visiting company facilities in their country of operation), and to engage with the rest of the investment team at RCM to ensure we are picking long-term winners in the emerging markets. | ||
| Closing Comments | |||
| 112. Why did your organisation join the PRI? | To publicly demonstrate our commitment to the integration of environmental, social and governance issues in investment decision making, both externally and internally. To be able to share in best practice with other asset managers striving to better understand the implication of ESG issues. | ||
| 113. Please describe the benefits you have enjoyed as a result of signing the PRI: | Signing the PRI has given us an additional level of access to other players in the ESG/RI space and thus further insight into international industry best practice. PRI interaction tools (emails, website, clearing house etc) have provided valuable information on the work of external research providers which could help us in our internal research endeavours and have given the RCM Sustainability Research team new ideas regarding our ESG integration potential. Becoming a PRI signatory has also enabled us to respond positively to asset owner's RFIs and RFPs that increasingly ask about status regarding the PRI. | ||
| 114. To what extent do you believe the PRI has succeeded in changing investor behaviour and/or raising awareness or capacity on RI/ESG issues? Do you have any examples you could share? | We believe it is still too early to assess whether or not the PRI has succeeded in changing investor behaviour on RI/ESG issues, although there might be some evidence to suggest it has succeeded in raising awareness due to the media attention the PRI has received and the number of asset owner's RFIs/RFPs which ask whether or not we, as asset managers, are signatories to the Principles. | ||
| 115. What are the top three activities the PRI Secretariat could undertake to enhance and encourage further implementation of the PRI by current and prospective signatories? | |||
| 1. | Could the secretariat in some way use the PRI tools (clearinghouse, website, emails) as some kind of one-stop-shop for the main SRI/RI/ESG initiatives already operating in the market. There is a lot going on and it would be useful to capture all activity in one place. | ||
| 2. | Ultimately, should there be some kind of benchmark which asset owners and managers should have to achieve before they can claim to be PRI signatories, thus encouraging better performance/more commitment. | ||
| 3. | n/a | ||
| 116. What are your top three PRI-related goals/priorities for 2008? | |||
| 1. | To continue to ask investment service providers to better integrate ESG factors into evolving research and analysis. | ||
| 2. | To better disclose how ESG issues are being integrated within our investment practices and to communicate with beneficiaries on our ESG research and commitment to the Principles. | ||
| 3. | To continue to support the development of ESG-related metrics and analysis. | ||
| 117. Please rank the six principles from most difficult to implement to least difficult to implement: | |||
| Most difficult 1 | Principle 3 | ||
| 2 | Principle 2 | ||
| 3 | Principle 4 | ||
| 4 | Principle 6 | ||
| 5 | Principle 5 | ||
| Least difficult 6 | Principle 1 | ||