Status under the EU Sustainable Finance Disclosure Regulation (SFDR) – Pan European Property Equities Fund

B. No Sustainable Investment Objective

This financial product promotes environmental or social characteristics but does not have as its objective sustainable investment.

C. Environmental or social characteristics of the financial product

The Fund promotes climate change mitigation through the adoption of GHG emission reductions targets and support for the UN Global Compact Principles (which cover matters including human rights, labour, corruption, and environmental pollution). The Fund does not use a reference benchmark to attain its environmental or social characteristics.

D. Investment Strategy

A typical investor will invest into this Fund to seek capital growth through investment in the pan European equity markets and specifically through exposure to property related securities.

Investors should read this section in conjunction with the Fund’s investment strategy (as set out in the section ‘Funds’ of the Prospectus).

The binding elements of the investment strategy described below are implemented as exclusionary screens within the Investment Manager’s order management system utilising third-party data provider(s) on an ongoing basis.

The companies in which investments are made are assessed by the Investment Manager to follow good governance practices.

The good governance practices of investee companies are assessed prior to making an investment and periodically thereafter in accordance with the Sustainability Risk Policy (“Policy”).

The Policy sets minimum standards against which investee companies will be assessed and monitored by the Investment Manager prior to making an investment and on an ongoing basis. Such standards may include, but are not limited to: sound management structures, employee relations, remuneration of staff and tax compliance.

The Policy can be found incorporated within Janus Henderson’s “ESG Investment Policy” in the “About Us – Environmental, Social and Governance (ESG)” section of the website at www.janushenderson.com.

In addition, the Investment Manager is a signatory to the UN Principles for Responsible Investment (UNPRI). As a signatory, the good governance practices of investee companies are also assessed by having regard to the UNPRI principles prior to making an investment and periodically thereafter.

E. Proportion of investments

No minimum environmental or social safeguards are applied to such investments. A minimum of 90% of the investments of the financial product are used to meet the environmental or social characteristics promoted by the financial product. Other assets may include cash or cash equivalents in addition to instruments held for the purposes of efficient portfolio management e.g. temporary holdings of index derivatives.

All investments of the financial product that are used to meet the environmental and/or social characteristics promoted by the financial product are direct investments.

No minimum environmental or social safeguards are applied to such investments.

F. Monitoring of environmental or social characteristics

The sustainability indicators used to measure the attainment of each of the environmental or social characteristics promoted by this financial product are:

• Overall Global UN Compact Compliance Status.
• % of portfolio: issuers with science-based emission targets, or a verified commitment to adopt science-based emissions targets.

The Front Office Controls & Governance team provide ongoing assurance that investment products are managed in line with documented sustainability commitments. Financial Risk review and challenge investment management in light of ESG-related risks, alongside traditional market risk metrics, and embed sustainability risk into the risk profiles. Investment Compliance implement exclusionary screening and monitor this on an ongoing basis in addition to elements of manual oversight where relevant.

G. Methodologies for environmental or social characteristics

Issuers are excluded if they are deemed to have failed to comply with the UN Global Compact Principles (which cover matters including human rights, labour, corruption, and environmental pollution).

The Fund also applies the Firmwide Exclusions Policy, which includes controversial weapons, as detailed under paragraph 10.15 of the section entitled “Investment Restrictions” to the Prospectus.

The Investment Manager actively engages with companies to encourage the adoption of science-based emission targets, or a verified commitment to adopt science-based emissions targets¹. The Investment Manager commits a minimum of 10% of companies within the portfolio having approved or committed targets and will monitor the progress of those companies against those targets.

For the purposes of the AMF doctrine, the extra-financial analysis or rating is higher than:

1. 1. 90% for equities issued by large capitalisation companies whose registered office is located in "developed" countries, debt securities and money market instruments with an investment grade credit rating, sovereign debt issued by developed countries.
   2. 75% for equities issued by large capitalisations whose registered office is located in "emerging" countries, equities issued by small and medium capitalisations, debt securities and money market instruments with a high yield credit rating and sovereign debt issued by "emerging" countries.

The Investment Manager may include positions in the Fund that, based on third-party data or screens, appear to fail the above criteria, where the Investment Manager believes that the third-party data is insufficient or inaccurate.

¹ Approved or verified by SBT – https://sciencebasedtargets.org, or equivalent

H. Data sources and processing

The JHI real estate team are selective in identifying data providers, preferring to utilise inputs principally from real estate specialist third party data providers such as GRESB, ICE and EPRA, alongside JHI’s chosen ESG (Environmental, Social and Governance) provider MSCI to inform their proprietary ESG framework.

Binding criteria applied to the fund to avoid investment in non-conforming companies and promote environmental characteristics are applied using MSCI. Proxy voting is provided by ISS, supported by the Central Governance and Stewardship team/Central JHI ESG team. Company engagement data is managed and covered by the investment team.

The team’s targeted ESG approach, focuses on Materiality, Data Quality and Dispersion when considering relevant factors. The team have conducted extensive on desk analysis to ensure confidence of data quality in selection of data providers. Where exclusions data is not available or the investment team disagrees with the assessment, the teamwork with an independent oversight body at JHI to validate the assessment. Depending on data availability, monthly and/or annual data feeds from several third-party data suppliers are downloaded by the investment team. The central JHI ESG team support across some of the data processes.

The proportion of data for a Financial Product that is estimated is constantly evolving.

I. Limitations to methodologies and data

The team’s proprietary framework relies heavily on their real estate expertise in the assessment of material issues and considers frameworks such as SASB. We recognise the limitations of scoring of complex issues with imperfect data, disclosures and varying methodologies. We feel active management and deep sector expertise are crucial to navigate this alongside the application of a robust and consistent process.

For the purposes of exclusionary screens for binding criteria, where there is data missing, evidence will be presented to an independent oversight body at JHI. as described above.

J. Due diligence

As detailed in the above ‘Methodologies for Environmental and Social Characteristics’ section, Issuers are excluded if they are deemed to have failed to comply with the UN Global Compact Principles (which cover matters including human rights, labour, corruption, and environmental pollution).

The Fund also applies the Firmwide Exclusions Policy, which includes controversial weapons, as detailed under paragraph 10.15 of the section entitled “Investment Restrictions” to the Prospectus.

The Investment Manager actively engages with companies to encourage the adoption of science-based emission targets, or a verified commitment to adopt science-based emissions targets¹. The Investment Manager commits a minimum of 10% of companies within the portfolio having approved or committed targets and will monitor the progress of those companies against those targets.

For the purposes of the AMF doctrine, the extra-financial analysis or rating is higher than:

1. 1. 1. 90% for equities issued by large capitalisation companies whose registered office is located in "developed" countries, debt securities and money market instruments with an investment grade credit rating, sovereign debt issued by developed countries.
      2. 75% for equities issued by large capitalisations whose registered office is located in "emerging" countries, equities issued by small and medium capitalisations, debt securities and money market instruments with a high yield credit rating and sovereign debt issued by "emerging" countries.

The Investment Manager may include positions in the Fund that, based on third-party data or screens, appear to fail the above criteria, where the Investment Manager believes that the third-party data is insufficient or inaccurate.

The JHI Sustainability Risk Policy sets out the firmwide ESG Integration Principles, Sustainable Investment Principles and Baseline Exclusions applied to investee companies. These exclusions are based on classifications provided by third-party data ESG data providers. This classification is subject to an investment research override in cases where sufficient evidence exists that the third-party field is not accurate or appropriate.

Each Investment desk completes their own due diligence processes ahead of making any investment decisions within their Article 8 funds, using internal and external tools and research. The Front Office Controls & Governance team provide ongoing assurance that investment products are managed in line with documented sustainability commitments. Financial Risk review and challenge investment management in light of ESG-related risks, alongside traditional market risk metrics. Investment Compliance implement exclusionary screening and monitor this on an ongoing basis in addition to elements of manual oversight where relevant.

¹ Approved or verified by SBT – https://sciencebasedtargets.org, or equivalent

K. Engagement Policies

In addition to the binding elements of the investment strategy described above, stewardship forms an integral and natural part of the team’s investment approach as active investors with investment specialists engrained in local markets.

The Firm supports a number of stewardship codes and broader initiatives around the world and is a signatory to the UK stewardship code. Details of JHI’s approach to Engagement can be found in the ‘ESG Investment Policy’ published under the ‘ESG Resource Library’ on the Janus Henderson website.

Janus Henderson has a Proxy Voting Committee, which is responsible for establishing positions on major voting issues and creating guidelines overseeing the voting process. The Committee is comprised of representatives of investments portfolio management, corporate governance, accounting, legal and compliance. Additionally, the Proxy Voting Committee is responsible for monitoring and resolving possible conflicts of interest with respect to proxy voting.

L. Designated Reference Benchmark

No index has been designated as a reference benchmark to meet the environmental or social characteristics promoted by this Article 8 Financial Product.

M. Principal Adverse Impacts (PAI)

PAIs are considered at the product level.¹ The table below sets out where PAI is considered through the use of exclusionary screens and engagement with companies:

Adverse Sustainability Indicator		Metric	How is PAI considered
Greenhouse gas emissions	GHG emissions	Scope 1 GHG emissions	Through engagement with companies
		Scope 2 GHG emissions	Through engagement with companies
	Carbon footprint	Carbon footprint	Through engagement with companies
	GHG Intensity of investee companies	HG intensity of investee companies	Through engagement with companies
Social and employee matters	Share of investments in investee companies involved in the manufacture or selling of controversial weapons	Exposure to controversial weapons (anti-personnel mines, cluster munitions, chemical weapons and biological weapons)	Exclusionary screen
	Violations of UN Global Compact principles and Organisation for Economic Cooperation and Development (OECD) Guidelines for Multinational Enterprises	Share of investments in investee companies that have been involved in violations of the UNGC principles or OECD Guidelines for Multinational Enterprises	Exclusionary screen

¹ This was effective as of 31 October 2022 and periodic reporting will commence from 1 January 2023 for the first reference period from 31 October 2022.

'Where the translated version of this disclosure text differs from the English version, the original English version prevails'