Status under the EU Sustainable Finance Disclosure Regulation (SFDR)

Janus Henderson Horizon US Sustainable Equity Fund

Legal Entity Identifier: 213800IO8UPHJ5RO8R12

A. Summary

The Fund is categorised as one which meets the provisions set out in Article 9 of SFDR as a product which has sustainable investment as its objective. It will make a 25% minimum of sustainable investments with an environmental objective in economic activities that do not qualify as environmentally sustainable under the EU Taxonomy. It will make a minimum of 25% of sustainable investments with a social objective. The sustainable investments do no significant harm to any environmental or social sustainable investment objective by considering certain principal adverse impacts and aligning with the OECD Guidelines for Multinational Enterprises and the UN Guiding Principles on Business and Human Rights. The Fund’s investment objective aims to provide capital growth over the long term by investing in US companies that contribute to the development of a sustainable global economy across environmental and social themes such as cleaner energy, water management and sustainable transport. The Fund does not use a reference benchmark to meets its sustainable investment objective.

The Investment Manager uses a pass/fail test meaning that each holding must meet all three of the requirements below:

1. based on revenue mapping to the Investment Manager’s themes, it contributes to an environmental or social objective;
2. it does not cause significant harm to any environmental or social sustainable investment objective; and
3. it follows good governance practices.

While each holding must pass the tests described above, the Investment Manager attaches a 25% weight to the consideration of each of (1) revenue mapping to an environmental or social objective; (2) causing no significant harm to any environmental objective; (3) causing no significant harm to any social objective; (4) governance practices.

This Fund seeks capital growth through investment in the global equity market and specifically through exposure to companies, whose products and services have a positive impact on the environment or society, thereby contributing to the development of a sustainable global economy.

The binding elements of the investment strategy described below are implemented as exclusionary screens within the Investment Manager’s order management system, or otherwise integrated within the investment selection and monitoring process utilising third-party data provider(s) and internal proprietary research on an ongoing basis. The exclusionary screens are implemented on both a pre and post trade basis enabling the Investment Manager to block any proposed transactions in an excluded security and identify any changes to the status of holdings when third-party data is periodically updated.

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 JHI Responsible Investment Policy, which incorporates our 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 Investment Manager attaches particular importance to the assessment of corporate culture, values, business strategy, board composition and diversity, tax transparency, audit, controls and remuneration. Generally accepted corporate governance standards may be adjusted for smaller organisations or to take account of local governance standards where appropriate at the discretion of the Investment Manager. The Policy can be found at www.janushenderson.com/esg-governance. 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.

A minimum of 90% of the investments of the financial product are expected to meet the sustainable investment objective of the financial product. The proportion of investments in the Fund which are aligned with the EU Taxonomy is 0%. The sustainability indicators used to measure the attainment of the sustainable investment objective of the Fund are: -

1. The Investment Manager uses selection criteria to ensure that the Fund invests only in companies that derive at least 50% of their current or future expected revenues from goods and services within the Investment Manager’s sustainable development themes, as set out below: -

Sustainable Development Themes
Efficiency	Sustainable property & finance
Cleaner energy	Safety
Water management	Quality of life
Environmental services	Knowledge & technology
Sustainable transport	Health

2. Carbon - Carbon Intensity Scope 1&2
3. Carbon - Carbon Footprint Scope 1&2
4. Overall UNGC Compliance Status
5. ESG Exclusionary screens

JHI has chosen MSCI as its primary data source for ESG (Environmental, Social and Governance) research. Where coverage gaps are identified, specialist ESG Data vendors or inhouse research may be used to complement the ESG research. This helps ensure consistent data and methodologies are given an ESG measure per security type and hence can be compared correctly in the portfolio construction process. Data coverage is directly driven by the coverage of the underlying ESG Data Provider. The attainment of the social and environmental characteristics is not wholly dependent on third party data, or any methodology limitations thereof and is typically also informed by proprietary research, engagement with investee companies where there might be relevant data gaps. The JHI Responsible Investment Policy, which incorporates JHI’s Sustainability Risk Policy, sets out the firmwide approach to ESG Integration, including JHI's Responsible Investment Principles for long-term investment success, our approaches to Stewardship and Engagement 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 9 funds, using internal and external tools and research. The attainment of the social and environmental characteristics is not wholly dependent on third party data, or any methodology limitations thereof and is typically also informed by proprietary research, engagement with investee companies where there might be relevant data gaps. Stewardship forms an integral and natural part of Janus Henderson’s long-term, active approach to investment management. Details of JHI’s approach to Engagement can be found in the ‘Responsible Investment Policy’ published under the 'ESG Resource Library’ on the Janus Henderson website.