Status under the EU Sustainable Finance Disclosure Regulation (SFDR) - Global Technology Leaders Fund

Janus Henderson Horizon Fund - Global Technology Leaders Fund

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.

A. Summary

This financial product promotes environmental or social characteristics 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 which can be found here. 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. Investors should read this section in conjunction with the Fund’s investment strategy (as set out in the section ‘Funds’ of the Prospectus).

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 within the Investment Manager’s order management system utilising third-party data provider(s) on an ongoing basis.

The good governance practices of investee companies are assessed prior to making an investment and periodically thereafter in accordance with the Sustainability Risk Policy (“Policy”). In addition, the Investment Manager is a signatory to the UN Principles for Responsible Investment (UNPRI).

A minimum of 85% of the investments of the financial product are used to meet the environmental or social characteristics promoted by the financial product. Other assets may include cash or cash equivalents in addition to instruments held for the purposes of efficient portfolio management, e.g. temporary holdings of index derivatives. No minimum environmental or social safeguards are applied to such investments.

All investment of the financial product used to meet the environmental or social characteristics promoted by the financial product are direct investments in investee companies.

The attainment of the environmental and social characteristics of the fund is measured via the below listed sustainability indicators.

• Carbon – Carbon Intensity Scope 1&2.
• Carbon – Carbon Footprint Scope 1&2.
• Overall UNGC Compliance Status.
• Number of companies engaged with in line with the Investment Manager’s engagement approach.
• ESG Exclusionary screens – see “Methodologies for environmental or social characteristics” below for details on the exclusions.

The Front Office Controls & Governance team provide ongoing assurance that investment products are managed in line with documented sustainability commitments. Financial Risk review and challenge investment management in light of ESG-related risks, alongside traditional market risk metrics, and embed sustainability risk into the risk profiles. Investment Compliance ensure that ESG-related activities are managed in line with regulatory requirements and expectations, and considered within our compliance framework.

The Investment Manager applies screens to exclude direct investment in issuers based on their involvement in certain activities. Specifically, issuers are excluded if they have any involvement with chemicals of concern or derive more than 5% of their revenue from the production of fossil fuels, nuclear weapons, tobacco, fur, alcohol, civilian armaments, intensive farming, nuclear power, gambling, pornography and animal testing (excluding medical testing). Issuers are also excluded if they are deemed to have failed to comply with the UNGC Principles.

The Fund relies on a number of third party data suppliers in combination with proprietary in-house research to attain the environmental or social characteristics promoted. Binding exclusions applied to the fund in order to avoid investment in certain activities with the potential to cause harm to human health and wellbeing or the environment are based on Vigeo Eiris data. The exclusions are monitored via a compliance monitoring system. Proxy voting is provided by ISS, supported by the Central Governance and Stewardship team/ Central JHI ESG team.

At the portfolio level, to ensure data quality of ESG data several processes take place. Issuer mapping consists of checks to remove duplicate issuers, unmapped issuers and varying issuer identifier methodology. Action Plans and Engagement data are checked via data deep dives.

Where exclusions data is not available or the investment team disagrees with the assessment, the dedicated sustainability analyst assists the investment analyst to determine if the potential holding is in breach of the fund’s exclusion policy. Where required, the analysis is then shared with an independent oversight body at JHI to validate the assessment. The proportion of estimated data is continually evolving and is supplemented by internal research provided by the investment team where necessary.

The investment manager recognises the limitations of static scoring of complex issues with imperfect data and disclosures and varying methodologies. Active management and deep sector and ESG expertise are crucial to navigate this.

The Investment Manager applies screens to exclude direct investment in issuers based on their involvement in certain activities. The JHI Sustainability Risk Policy sets out the firmwide ESG Integration Principles, Sustainable Investment Principles and Baseline Exclusions applied to investee companies. 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.

Each Investment desk completes their own due diligence processes ahead of making any investment decisions within their Article 8 funds, using internal and external tools and research. The Front Office Controls & Governance team provide ongoing assurance that investment products are managed in line with documented sustainability commitments. Financial Risk review and challenge investment management in light of ESG-related risks, alongside traditional market risk metrics, and embed sustainability risk into the risk profiles.

The investment manager takes a pro-active approach to communicating views to companies and seeking improvements in performance and standards of corporate responsibility and governance and supports core principles such as disclosure, transparency and consistency, while promoting E and S.

See Janus Henderson’s ESG Investment Policy at www.janushenderson.com and the strategies V&E policy & report for more information.