Status under the EU Sustainable Finance Disclosure Regulation (SFDR)

B. No significant harm to the sustainable investment 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 Investment Manager uses a number of sources/methods to consider the mandatory indicators for principal adverse impacts on sustainability factors (“PAIs”) under the EU Sustainable Finance Disclosure Regulation (SFDR), to determine that its sustainable investments do not cause significant harm to relevant environmental or social objectives. Depending on the indicator, the Investment Manager uses one or more of the following approaches:

1. Each underlying investment’s activities and reported metrics are screened against significant harm criteria defined by JHI referring to the relevant mandatory PAIs set out under SFDR, dependant on the company’s performance relative to pre-set house level exclusionary criteria (which may be quantitative or qualitative in nature).
2. Operational ESG assessment - company specific ESG issues are identified and their overall level of exposure to material impacts and risks are assessed against ongoing remediation of those risks.

As at 3 December 2024, the Investment Manager considers the mandatory indicators for PAIs as follows:

GHG Emissions	Issuers are excluded if they derive any revenue e from fossil fuels. (The Investment Manager may invest in issuers generating power from natural gas if the issuer’s strategy involves a transition to renewable energy power generation and they have a carbon intensity aligned with the Paris Agreement. Companies that derive revenues that generate high carbon emissions or exploit non-renewable resources, either directly or in their supply chain are excluded, unless the company can demonstrate an outstandingly positive response toward environmental and social concerns. This includes industries such as cement, fishing, mining, palm oil and timber. When the activity relates to a company’s operations, the Investment Manager will seek to gain comfort that the company is taking action to improve its performance or is managing it in an exemplary fashion. Any company with a persistent record of misconduct relating to GHG emissions will be excluded unless there is clear evidence of significant progress. The Investment Manager aims to maintain a carbon footprint and carbon intensity that is at least 20% below the S&P 500 primarily through the exclusion of high emitting sectors, the consideration of carbon emissions as part of the pre-investment ESG analysis, and the engagement program with portfolio companies in which the investment Manager prioritises climate strategy and emissions reductions.
Carbon Footprint
GHG Intensity of Investee Companies
Exposure to companies active in fossil fuel sector
Share of Non-Renewable energy consumption and production	As part of the pre-investment ESG assessment, where data is available, the Investment Manager reviews a company’s proportion of non-renewable energy consumption and production. The Investment Manager seeks to engage to improve performance wherever data is not available, or wherever the proportion of non-renewable energy consumed or produced is more than 20% above the benchmark average for the sector.
Energy Consumption intensity per high impact climate sector	As part of the pre-investment ESG assessment for investments in companies in high impact climate sectors, where data is available, the Investment Manager reviews a company’s energy consumption. The Investment Manager seeks to engage to improve performance wherever data is not available, or wherever energy consumption is more than 20% above the benchmark average for the sector.
Activities negatively affecting bio diversity sensitive areas	The Investment Manager avoids investing in sectors and companies with exposure to activities that have high risk with regard to negative impacts on biodiversity, including chemicals of concern, non- medical animal testing, the sale of fur, genetically modified organisms and intensive farming at a 5% threshold. The Investment Manager also avoids investment in palm oil, timber, fishing, and mining which is avoided subject to a 5% threshold unless the company can demonstrate an outstanding positive response to environmental and social concerns as part of the pre-investment ESG assessment.
Emissions to water	The Investment Manager will engage if water emissions are deemed material and the relevant metric is not reported or if the reported data is of insufficient quality. A review of recent controversies is included in the assessment. The Investment Manager’s process is as follows: The dedicated sustainability analyst assesses if water emissions is material to the sub-sector/company in question The data, including reporting to CDP on water, is flagged as part of the internal data monitoring A data quality check is conducted If there is no disclosure, if data quality is deemed insufficient, or if a material outstanding controversy is deemed unresolved, the Investment Manager will engage
Hazardous waste ratio	The Investment Manager will engage if hazardous waste ratio is deemed material, if the relevant metric is not reported, or if the reported data is of insufficient quality. An assessment of recent controversies is included in the assessment. The Investment Manager’s process is as follows: The dedicated sustainability analyst assesses if hazardous waste is material to the sub-sector/company in question The data is flagged as part of the internal data monitoring A data quality check is conducted If there is no disclosure, if data quality is deemed insufficient, or if a material outstanding controversy is deemed unresolved, the Investment Manager will engage
Violations of UN Global Compact principles and Organisation for Economic Cooperation and Development (OECD) Guidelines for Multinational Enterprises	Issuers are excluded if they have failed align with the OECD Guidelines for Multinational Enterprises or failed to comply with the UN Global Compact Principles.
Lack of processes and compliance mechanisms to monitor compliance with UN Global Compact principles and OECD Guidelines for Multinational Enterprises	Violators are excluded as noted above.The Investment Manager also monitors a UNGC and OECD MNE watchlist and engages with companies if they are included on the UNGC or OECD MNE watchlist for non-compliance.
Unadjusted gender pay gap	The Investment Manager will engage if a company fails to report on this metric, or if the reported data is of insufficient quality. The Investment Manager’s process is as follows: The dedicated sustainability analyst identified any recent controversies regarding gender-related discriminatory pay practices The data is flagged as part of the internal data monitoring A data quality check is conducted If there is no disclosure, if data quality is deemed insufficient, or if a material outstanding controversy is deemed unresolved, the Investment Manager will engage"
Board gender diversity	The Investment Manager engages with companies whose boards flag as under 30% female or are homogenously gendered.
Exposure to controversial weapons (anti- personnel mines, cluster munitions, chemical weapons and biological weapons)	Investment is not permitted in entities involved in the current manufacture of, or minority shareholding of 20% or greater in a manufacturer of controversial weapons., namely: (i) Cluster munitions; (ii) Anti-Personnel mines; (iii) Chemical weapons; (iv) Biological weapons.

Screens are applied to avoid investing in issuers if the Investment Manager considers they have failed to align with the OECD Guidelines for Multinational Enterprises; and the UN Guiding Principles on Business and Human Rights, including the principles and rights set out in the eight fundamental conventions identified in the Declaration of the International Labour Organisation on Fundamental Principles and Rights at Work and the International Bill of Human Rights. If an issuer already held in the fund breaches the screen it will be divested within 90 days unless a continued investment case can be made which would need to be agreed by the ESG Oversight Committee. This could be for example if the screening data provider is believed to have based the assessment on incorrect information.

C. Sustainable investment objective of the financial product

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.

D. Investment Strategy

This Fund seeks capital growth through investment in the US equity market and specifically through exposure to US 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.

Periodic desk reviews are undertaken to: review and validate the application of positive screens including revenue mapping to sustainability themes and to review the validity of thematic mapping to the sustainability themes; validate the application of negative screens utilised by the strategy; and to verify engagement activity including the application of formal action plan completion or tracking as relevant. The results of these periodic reviews are reported to an oversight committee including any necessary escalations where additional stakeholder views are necessary.

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.

E. Proportion of investments

A minimum of 90% of the investments of the financial product are expected to meet the sustainable investment objective of the financial product.

The Investment Manager’s Sustainable Investment Approach includes revenue mapping to environmental and social themes to determine whether an investment contributes to an environmental or social objective. The Fund will have a minimum of 25% invested in sustainable investments with an environmental objective and 25% in sustainable investments with a social objective.

The remaining assets may include investments for certain specific purposes such as hedging or liquidity (i.e. cash/cash equivalents and temporary holdings of index derivatives) and  which, in order to ensure that they do not prevent the financial product from attaining its sustainable investment objective, have to meet minimum environmental or social safeguards including that they do no significant harm and align with the OECD Guidelines for Multinational Enterprises and the UN Guiding Principles on Business and Human Rights, where relevant.

The Fund does not use derivatives to attain its sustainable investment objective.

The proportion of investments in the Fund which are aligned with the EU Taxonomy is 0%. Although the EU Taxonomy provides an ambitious framework to determine the environmental sustainability of economic activities, the EU Taxonomy does not comprehensively cover all industries and sectors, or all environmental objectives. The Investment Manager uses its own methodology to determine whether investments selected for the Fund are environmentally sustainable in accordance with the SFDR rules.

F. Monitoring of sustainable investment objective

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
   This represents the company's most recently reported or estimated Scope 1 + Scope 2 greenhouse gas emissions normalized by sales, which allows for comparison between companies of different sizes.
3. Carbon - Carbon Footprint Scope 1&2
   This represents the company's most recently reported or estimated Scope 1 + Scope 2 greenhouse gas emissions (if available). Scope 1 emissions are those from sources owned or controlled by the company, typically direct combustion of fuel as in a furnace or vehicle. Scope 2 emissions are those caused by the generation of electricity purchased by the company.
4. Overall UNGC Compliance Status
5. ESG Exclusionary screens - see “G. Methodologies” below for details on the exclusions
6. Data Sources and processing – as further described under Section H

Details of how the sustainable investments do not cause significant harm to any environmental or social sustainable investment objectives, and the policy to assess good governance practices of the investee companies, are included above.

The JHI ESG Investment Policy, which incorporates JHI’s Sustainability Risk Policy sets out the firmwide ESG Integration Principles, responsible 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 9 funds, using internal and external tools and research.

The Front Office Controls & Governance team provide ongoing assurance where required, that we can evidence Investment products being managed in line with documented sustainability commitments where automated controls and/or 3rd party data are not available. 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

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.

The Fund’s investment universe is determined by the application of binding positive screening criteria based on the sustainable investment themes of the Investment Manager noted previously. The Investment Manager uses a proprietary methodology to ensure that companies the Fund invests in derive at least 50% of their current or future expected revenues from goods and services aligned with these sustainability themes and as noted above, has a process in place to determine that its sustainable investments don’t significantly harm other relevant environmental or social objectives.

The Investment Manager applies screens to exclude issuers if they are deemed to have failed to comply with the UNGC Principles (which cover matters including human rights, labour, corruption, and environmental pollution).

In addition, the Investment Manager applies screens to exclude direct investment in corporate issuers based on their involvement in certain activities. Specifically, issuers are excluded if they derive any revenue from controversial weapons*, fossil fuels**, or tobacco production. Issuers are also excluded if they derive more than 5% of their revenue from: alcohol; non-medical animal testing; civilian firearms and ammunition; conventional weapons; nuclear power generation; fur; gambling; chemicals of concern; genetically modified organisms; human stem cell research; pornography; intensive farming; and tobacco distribution, retail licensing and supply.

*the Fund applies enhanced controversial weapon screening in addition to the firmwide exclusions which screen a broader range of activities.

**The Investment Manager may invest in issuers generating power from natural gas if the issuer’s strategy involves a transition to renewable energy power generation and they have a carbon intensity aligned with the Paris Agreement.

The Fund also applies the Firmwide Exclusions Policy (see “Firmwide Exclusions” in the JHI Responsible Investment Policy”), which includes controversial weapons.

The Investment Manager anticipates that the screening criteria will decrease the Fund’s investment universe by at least 30%.

The Investment manager seeks to achieve a better result on the following two sustainability indicators when compared to the corresponding benchmark:

The Investment Manager aims to maintain a carbon footprint and carbon intensity that is at least 20% below the S&P 500 Index.

The Investment Manager aims to maintain a weighted average exposure to companies with notable ESG controversies that is below the S&P 500 Index.

While each holding must pass the Investment Managers pass/fail test 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.

In addition to the above the Investment Manager applies screens against the activities defined, as at the date of this prospectus, in Article 12 Exclusions for EU Paris-aligned Benchmarks of the Commission Delegated Regulation (EU) 2020/1818 of 17 July 2020. Specifically, companies are excluded if they have any involvement in the following:

1. companies involved in any activities related to controversial weapons;
2. companies involved in the cultivation and production of tobacco;
3. companies that benchmark administrators find in violation of the United Nations Global Compact (UNGC) principles or the Organisation for Economic Cooperation and Development (OECD) Guidelines for Multinational Enterprises;
4. companies that derive 1 % or more of their revenues from exploration, mining, extraction, distribution or refining of hard coal and lignite;
5. companies that derive 10 % or more of their revenues from the exploration, extraction, distribution or refining of oil fuels;
6. companies that derive 50 % or more of their revenues from the exploration, extraction, manufacturing or distribution of gaseous fuels;
7. companies that derive 50 % or more of their revenues from electricity generation with a GHG intensity of more than 100 g CO2 e/kWh.

For the purposes of point (a), controversial weapons shall mean controversial weapons as referred to in international treaties and conventions, United Nations principles and, where applicable, national legislation.

In addition, the Investment Manager applies screens to exclude direct investment in:

• any issuer whose head office is located in a country or territory included in the latest available version of the EU list of countries and territories not cooperating on tax issues.
• any issuer whose registered office is domiciled in a country or territory on the Financial Action Task Force (FATF) blacklist or greylist.

The Investment Manager may invest in companies that would be excluded by the screens described above if the Investment Manager believes, based on its own research and as approved by its ESG Oversight Committee, that the third-party data used to apply the exclusions is insufficient or inaccurate.

The Investment Manager may consider that the data is insufficient or inaccurate if, for example, the third-party data provider research is historic, vague, based on out of date sources, or the investment manager has other information to make them doubt the accuracy of the research.

If the Investment Manager wishes to challenge the third-party data, then the challenge is presented to a cross-functional ESG Oversight Committee who must sign off on the “override” of the third-party data.

If a third party data provider does not provide research on a specific issuer or excluded activity, the Investment Manager may invest if, through its own research, it is satisfied that the issuer is not involved in the excluded activity.

H. Data sources and processing

The Fund 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.

JHI has built a centralised proprietary research alignment process. The central research alignment process aligns data at three different levels:

1. Entity Level,
2. Position Level, and
3. Fund Level.

The research alignment and mapping capability is critical to JHI's ESG methodology, as we recognize a security could inherit the ESG information from the issuing legal entity, however, some ESG risks will be instrument specific.

JHI applies a series of Data Quality rules to ensure the integrity of the data being ingested into the central research alignment solution. JHI data that is not aligned correctly to the definition as provided by the data vendor is not ingested into the central cloud-based data warehouse and exceptions are raised. These exceptions are monitored and remediated by a central support team. Remediation includes challenging the data provider or internal operations supporting internally managed Systems of Records. Where appropriate the Data Owner responsible and accountable for the data is notified through the internal Data Governance process to resolve outstanding exceptions.

JHI receives weekly automated data feeds from external ESG Data vendors, which are ingested into a cloud-based data warehouse.

Some data used to support binding criteria as received from external providers may be estimated data. For positions not covered by the external data provider, proprietary research may be used. This could range from proprietary research alignment against the external data vendor to written confirmation from the issuing entity that it aligns to the binding criteria. The appropriateness of the evidence provided is assessed by an independent body at JHI.

 I. Limitations to methodologies and data

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.

JHI’s internal data structure provides sufficient flexibility to incorporate proprietary research or adapt evaluations to future requirements.

JHI is aware of data gaps in ESG Research for non-traditional asset classes compared to mainstream asset classes such as equities and debt instruments.

J. Due diligence

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 Front Office Controls & Governance team provide ongoing assurance where required, that we can evidence Investment products being managed in line with documented sustainability commitments where automated controls and/or 3rd party data are not available. 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 ensure that ESG-related activities are managed in line with regulatory requirements and expectations and considered within our compliance framework.

K. Engagement Policies

In addition to the binding elements of the investment strategy described above, 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.

The Firm supports a number of stewardship codes and broader initiatives around the world and is a signatory to the UK Stewardship Code.

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. Attainment of the sustainable investment objective

The Fund does not use a reference benchmark to meets its sustainable investment objective.

Principal adverse impacts (PAIs)

As at 3 December 2024, the Investment Manager considers the following principal adverse impacts on sustainability factors (“PAIs”) for this Fund:

Adverse Sustainability Indicator		Metric	How is PAI considered
Greenhouse gas emissions	GHG emissions	Scope 1 GHG emissions	Exclusionary screens
		Scope 2 GHG emissions	Exclusionary screens
	Carbon footprint	Carbon footprint	Exclusionary screens
	GHG Intensity of investee companies	GHG intensity of investee companies	Exclusionary screens
	Exposure to companies active in the fossil fuel sector	Share of investments in companies active in the fossil fuel sector	Exclusionary screens
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 screens
	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 screens

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