Janus Henderson Horizon Global Technology Leaders Fund

Legal entity identifier:213800QJI37OX4A6KI81

A. Summary

The Fund is categorised as one which meets the provisions set out in Article 8 of SFDR as a product which promotes environmental and/or social characteristics and invests in companies with good governance practices, but does not have as its objective sustainable investment.

The Fund promotes climate change mitigation, support for the UNGC Principles (which cover matters including human rights, labour, corruption, and environmental pollution).

The Fund applies proxy voting and engagement in line with the Investment Manager’s policy. The Fund seeks also to avoid investments in certain activities with the potential to cause harm to human health and wellbeing or the environment by applying binding exclusions.

The Fund does not use a reference benchmark to attain its environmental or social characteristics.

This Fund to seeks capital growth through investment in the global equity market and specifically through exposure to technology related securities.

Companies that the Investment Manager believes may be facing potential environmental or societal issues are subject to active engagement, the exercise of voting rights, and the proposal of action plans (where appropriate), in order to identify sustainability risks and help influence remedial change.

If the Investment Manager has concerns that a company is failing to sustain appropriate environmental and/or social credentials, it will take appropriate remedial actions, which may include engagement or divestment.

The binding elements of the investment strategy described below are implemented as exclusionary screens which are coded into the compliance module of the Investment Manager’s order management system utilising third-party data provider(s) on an ongoing basis. The exclusionary screens are implemented on both a pre and post trade basis enabling the sub investment advisor 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 Investment Manager uses specific screens to help achieve some of the promoted characteristics. For example – to promote climate change mitigation, screens are applied to avoid investment in certain high carbon activities, and it is expected that this will result in the fund having a lower carbon profile. Another example is that to promote support for the UNGC Principles, screens are applied so that the Fund does not invest in issuers that are in breach of the UNGC and OECD MNE Principles based on third party data and/or internal research.

The Investment Manager applies screens to exclude issuers if they are deemed to have failed to comply with the UNGC and OECD MNE 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: production of alcohol; non-medical animal testing; civilian firearms and ammunition; conventional weapons; nuclear power generation; fur production; gambling operations; chemicals of concern; 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 Fund also applies the Firmwide Exclusions Policy (see “Firmwide Exclusions” in the “JHI Responsible Investment Policy”), which includes controversial weapons.

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

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 assesses each company held by the Fund in relation to its impact on the environment and society in addition to an analysis of the governance risks it exhibits.

The Investment Manager may only 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.

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 that consistent data and methodologies are used given an ESG measure per security type and hence can be compared correctly in the portfolio construction process.

The JHI Responsible Investment Policy, which incorporates JHI’s Sustainability Risk Policy, sets out the firmwide approach to ESG Integration Principles, including JHI’s Responsible Investment Principles for long-term investment success, our approaches to Stewardship and Engagement and Baseline Exclusions applied to investee companies.

Janus Henderson Horizon Pan European Mid and Large Cap Fund

Legal entity identifier: 213800FJ6CA2XYR8B223

A. Summary

The Fund is categorised as one which meets the provisions set out in Article 8 of SFDR as a product which promotes environmental and/or social characteristics and invests in companies with good governance practices, but does not have as its objective sustainable investment.

The Fund promotes climate change mitigation and avoiding issuers with a high carbon intensity, and which do not have a credible transition strategy. The Fund also seeks to avoid investments in certain activities with the potential to cause harm to human health and wellbeing by applying binding exclusions and promotes support for UNGC 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.

The Fund seeks capital growth through investment in the European (including UK) equity markets.

The binding elements of the investment strategy described below are implemented as exclusionary screens which are coded into the compliance module of the Investment Manager’s order management system utilising a third-party data provider on an ongoing basis. The exclusionary screens are implemented on both a pre and post trade basis enabling the sub investment advisor 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.

Two elements of the binding criteria referenced below regarding issuers with a high carbon intensity are not available as automated data points and are evidenced by external or in-house research:

• In the specific case of the airlines sector, the company has made significant aircraft fleet investment to reduce carbon output (that is to have a younger than average fleet age); or
• The issuer has committed 30% of future gross capex and/or research and development to sustainability aligned projects.

The Investment Manager uses specific screens to help achieve some of the promoted characteristics. For example – to promote climate change mitigation, screens are applied to avoid investment in certain high carbon activities, and it is expected that this will result in the fund having a lower carbon profile.

The Investment Manager applies screens to exclude direct investment in issuers based on their involvement in certain activities. Specifically, issuers are excluded if they derive more than 10% of their revenue from oil sands extraction, arctic oil and gas, thermal coal extraction and power generation, palm oil, or tobacco.

The Investment Manager will only invest or continue to be invested in issuers in breach of UNGC principles if it determines that they are on track to improve.  In which case the Investment Manager will engage with those issuers over a period of 24 months from a “fail” rating.  After this time if the issuer continues to “fail” to meet UNGC principles, the Investment Manager will divest and screens will be applied to exclude the issuer.

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

The Investment Manager may invest in issuers with a high carbon intensity¹ (other than those excluded as described above) if it determines that such issuers have a credible transition strategy, based on its proprietary methodology described below.

In accordance with the Investment Manager’s proprietary methodology, a company will only be considered as having a credible transition strategy if it has at least one of the following:

• a science-based emissions target or a verified commitment to adopt a science-based emissions target (approved or verified by SBT – https://sciencebasedtargets.org/ or equivalent ); or
• In the specific case of the airlines sector, made significant aircraft fleet investment to reduce carbon output (that is to have a younger than average fleet age); or
• has committed 30% of future gross capex and/or research and development to sustainability aligned projects, in accordance with the Investment Manager’s methodologies.

If a company does not currently have a credible transition strategy in place, the Investment Manager may still invest if the company demonstrates superior ESG risk management by achieving an ESG rating of AA or higher (rating by MSCI – https://www.msci.com/ or equivalent).

Additional criteria may also be applied in assessing the validity of the transition strategy.

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

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 only 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.

JHI has chosen MSCI’s 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 ensures helps ensure that consistent data and methodologies are used given an ESG measure per security type and hence can be compared correctly in the portfolio construction process.

The JHI Responsible Investment Policy, which incorporates JHI’s Sustainability Risk Policy, sets out the firmwide approach to ESG Integration Principles, including JHI’s Responsible Investment Principles for long-term investment success, our approaches to Stewardship and Engagement and Baseline Exclusions applied to investee companies.

¹ High carbon intensity refers to the 5% of highest emitting companies in the Western Europe (EX UK) stocks above EUR1bn market cap

Janus Henderson Horizon Responsible Resources Fund

Legal entity identifier: 213800SUMWA13II54903

A. Summary

The Fund is categorised as one which meets the provisions set out in Article 8 of SFDR as a product which promotes environmental and/or social characteristics and invests in companies with good governance practices, but does not have as its objective sustainable investment.

The Fund promotes climate change mitigation, support for the UNGC principles (which cover matters including human rights, labour, corruption and environmental pollution) and investment in companies aligned with the following sustainability themes: energy transition; sustainable mobility; sustainable industry; sustainable agribusiness; and carbon reduction. The Fund does not use a reference benchmark to attain its environmental or social characteristics.

This Fund seeks capital growth through investment in the global equity markets and specifically through exposure to the natural resources sector.

The binding elements of the investment strategy described below are implemented as exclusionary screens which are coded into the compliance module of the Investment Manager’s order management system utilising third-party data provider(s) 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 binding criteria to gain exposure to companies aligned to at least one of the sustainability themes referenced above is overseen by periodic desk reviews to identify that sufficient research has been undertaken and documented to evidence that issuers within the Fund make a positive contribution towards and have been correctly mapped to the sustainability themes referenced below.

The Investment Manager uses specific screens to help achieve some of the promoted characteristics. For example – to promote climate change mitigation, screens are applied to avoid investment in certain high carbon activities, and it is expected that this will result in the fund having a lower carbon profile.  Another example is that to promote support for the UNGC Principles, screens are applied so that the Fund does not invest in issuers that are in breach of the UNGC Principles based on third party data and/or internal research.

The Investment Manager applies screens to exclude direct investment in issuers based on their involvement in certain activities. Specifically, issuers are excluded if they derive more than 10% of their revenue from the production of fossil fuels. Issuers are also excluded 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 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.

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

The investment strategy of the Fund seeks to gain an at least 80% exposure to companies aligned with at least one of the following sustainability themes: energy transition; sustainable mobility; sustainable industry; sustainable agribusiness; and carbon reduction.

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

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 only 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.

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 that consistent data and methodologies are used given an ESG measure per security type and hence can be compared correctly in the portfolio construction process.

The JHI Responsible Investment Policy, which incorporates JHI’s Sustainability Risk Policy, sets out the firmwide approach to ESG Integration Principles, including JHI’s Responsible Investment Principles for long-term investment success, our approaches to Stewardship and Engagement and Baseline Exclusions applied to investee companies.

Janus Henderson Absolute Return Fund

Legal entity identifier: 213800KHR3DA4ELZN939

A. Summary

The Fund is categorised as one which meets the provisions set out in Article 8 of SFDR as a product which promotes environmental and/or social characteristics and invests in companies with good governance practices. Whilst the Fund does not have as its objective a sustainable investment, it will have a minimum proportion of 5% of sustainable investments with a social objective and an environmental objective in economic activities that do not qualify as environmentally sustainable under the EU Taxonomy. See “B. No Sustainable Investment Objective” below for further details.

The Fund promotes support for the UNGC principles (which cover matters including human rights, labour, corruption, and environmental pollution). The Fund also seeks to avoid investments in certain activities with the potential to cause harm to human health and wellbeing by applying binding exclusions. The Fund does not use a reference benchmark to attain its environmental or social characteristics.

In addition, the Fund invests a minimum of 5% of its deployed capital in sustainable investments. The sustainable investments held by the Fund may contribute to addressing a range of environmental and/or social issues set out in the UN Sustainable Development Goals. An investment will be determined to make a positive contribution to an environmental or social objective where its business activity or practices positively contribute to environmental and/or social objectives.

This Fund seeks a positive absolute return through global equity markets and specifically through a majority investment in the UK.

The binding elements of the investment strategy described below are implemented as exclusionary screens on the entire long position, both core (long-term, fundamentally driven positions) and tactical (short-term, trading oriented positions) long positions which are coded into the compliance module of the Investment Managers order management system utilising third-party data provider(s) on an ongoing basis. The exclusionary screens are implemented on both a pre and post trade basis enabling the sub investment advisor 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 Investment Manager applies screens to its entire long position, both core and tactical long positions to exclude direct investment in issuers based on their involvement in certain activities. Specifically, issuers are excluded if they derive more than 10% of their revenue from thermal coal extraction, shale energy extraction, oil sands extraction, or arctic oil and gas drilling or exploration. Issuers are also 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 Investment Manager applies screens only to its core long positions to exclude ESG laggards.

The Investment Manager carries out its review from an ESG perspective (i.e. ‘extra-financial analysis’) on at least 90% of its entire long position, both core and tactical  long positions.

Further, the Investment Manager uses a pass/fail test to determine investments which are deemed sustainable investments, meaning that each holding must meet all three of the requirements below:

1. 1. based on revenue mapping to UN Sustainable Development Goals or having a carbon emissions target approved by the Science Based Targets initiative (SBTi), 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 also applies the Firmwide Exclusions Policy (see “Firmwide Exclusions” in the “JHI Responsible Investment Policy”), which includes controversial weapons.

The Investment Manager may only 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.

JHI has chosen MSCI’s 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 ensures helps ensure that consistent data and methodologies are used given an ESG measure per security type and hence can be compared correctly in the portfolio construction process.

The JHI Responsible Investment Policy, which incorporates JHI’s Sustainability Risk Policy, sets out the firmwide approach to ESG Integration Principles, including JHI’s Responsible Investment Principles for long-term investment success, our approaches to Stewardship and Engagement and Baseline Exclusions applied to investee companies.

Janus Henderson Horizon Euroland Fund

Legal entity identifier: 213800BBUJB2HJ1RZ384

A. Summary

The Fund is categorised as one which meets the provisions set out in Article 8 of SFDR as a product which promotes environmental and/or social characteristics and invests in companies with good governance practices, but does not have as its objective sustainable investment.

The Fund promotes climate change mitigation and avoiding issuers with a high carbon intensity, and which do not have a credible transition strategy. The Fund also seeks to avoid investments in certain activities with the potential to cause harm to human health and wellbeing by applying binding exclusions and promotes support for UNGC 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.

The Fund seeks capital growth through investment in the ‘Euroland’ equity market.

The binding elements of the investment strategy described below are implemented as exclusionary screens which are coded into the compliance module of the Investment Manager’s order management system utilising a third-party data provider on an ongoing basis. The exclusionary screens are implemented on both a pre and post trade basis enabling the sub investment advisor 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.

Two elements of the binding criteria referenced below regarding issuers with a high carbon intensity are not available as automated data points and are evidenced by external or in-house research:

• In the specific case of the airlines sector, the company has made significant aircraft fleet investment to reduce carbon output (that is to have a younger than average fleet age); or
• The issuer has committed 30% of future gross capex and/or research and development to sustainability aligned projects.

The Investment Manager uses specific screens to help achieve some of the promoted characteristics. For example- to promote climate change mitigation, screens are applied to avoid investment in certain high carbon activities, and it is expected that this will result in the fund having a lower carbon profile.

The Investment Manager applies screens to exclude direct investment in issuers based on their involvement in certain activities. Specifically, issuers are excluded if they derive ⁽¹⁾ any revenue from the production, manufacture, management or storage of fissile materials used in/for nuclear weapons. ⁽²⁾ more than 10% of their revenue from oil sands extraction, arctic oil and gas, thermal coal extraction and power generation, palm oil, or tobacco.

The Investment Manager will only invest or continue to be invested in issuers in breach of UNGC principles if it determines that they are on track to improve. In which case the Investment Manager will engage with those issuers over a period of 24 months from a “fail” rating. After this time if the issuer continues to “fail” to meet UNGC principles, the Investment Manager will divest and screens will be applied to exclude the issuer.

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

The Investment Manager may invest in issuers with a high carbon intensity1 (other than those excluded as described above) if it determines that such issuers have a credible transition strategy, based on its proprietary methodology described below.

In accordance with the Investment Manager’s proprietary methodology, a company will only be considered as having a credible transition strategy if it has at least one of the following:

• a science-based emissions target or a verified commitment to adopt a science-based emissions target (approved or verified by SBT – https://sciencebasedtargets.org/ or equivalent); or
• In the specific case of the airlines sector, made significant aircraft fleet investment to reduce carbon output (that is to have a younger than average fleet age); or
• has committed 30% of future gross capex and/or research and development to sustainability aligned projects, in accordance with the Investment Manager’s methodologies.

If a company does not currently have a credible transition strategy in place, the Investment Manager may still invest if the company demonstrates superior ESG risk management by achieving an ESG rating of AA or higher (rating by MSCI – https://www.msci.com/ or equivalent).

Additional criteria may also be applied in assessing the validity of the transition strategy.

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

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 only 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.

JHI has chosen MSCI’s 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 ensures helps ensure that consistent data and methodologies are used given an ESG measure per security type and hence can be compared correctly in the portfolio construction process.

The JHI Responsible Investment Policy, which incorporates JHI’s Sustainability Risk Policy, sets out the firmwide approach to ESG Integration Principles, including JHI’s Responsible Investment Principles for long-term investment success, our approaches to Stewardship and Engagement and Baseline Exclusions applied to investee companies.

¹High carbon intensity refers to the 5% of highest emitting companies in the Western Europe (EX UK, Switzerland, Denmark, Norway and Sweden) stocks above EUR1bn market cap.

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

Janus Henderson Horizon Sustainable Future Technologies Fund

Legal Entity Identifier: 2138006VK6JR3K2AV795

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 technology-related companies that contribute to the development of a sustainable global economy across environmental and social themes. 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 technology-related 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 Fund integrates environmental, social and governance factors into the bottom-up, fundamental company analysis and valuation. Fundamental research enables the Investment Manager to navigate the hype cycle1 of sustainable technology as well as identifying companies that are making a positive contribution to environmental and social themes. The investment process considers and monitors climate and environmental indicators as well as social and employee matters as part of its investment due diligence process and responds to these through exercising voting rights, active engagement and action plans that have a bearing on investment decisions.

Periodic desk reviews are undertaken to: review and validate the application of positive screens including revenue mapping to sustainable technology themes and to review the validity of thematic mapping to the sustainable technology 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.

A minimum of 90% of the investments of the financial product are used 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 technology themes, as set out below:

Sustainable Technology Themes
Clean Energy Technology	Sustainable transport
Resource and Productivity Optimisation	Digital Democratisation
Smart Cities	Tech Health
Low Carbon Infrastructure	Data Security

1. Carbon – Carbon Intensity Scope 1&2
2. Carbon – Carbon Footprint Scope 1&2
3. Overall UNGC and OECD MNE Compliance Status
4. % of the portfolio aligned with the Fund’s sustainability themes
5. Number of companies engaged with in line with the Investment Manager’s engagement approach.
6. ESG Exclusionary screens

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. 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.

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.

Janus Henderson Horizon Global Sustainable Equity Fund

Legal Entity Identifier: 213800BZJWP55PIIYD4

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 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 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. 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.