Status under the EU Sustainable Finance Disclosure Regulation (SFDR) – Global Real Estate Equity Income Fund

Janus Henderson Capital Fund – Global Real Estate Equity Income 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 through the adoption of GHG emission reductions targets and support for the UN Global Compact principles (which cover matters including human rights, labour, corruption, and environmental pollution). The Fund 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.

The binding elements of the investment strategy described below are implemented as exclusionary screens within the Sub-Investment Adviser’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 Sub-Investment Adviser is a signatory to the UN Principles for Responsible Investment (UNPRI).

A minimum of 90% of the investments of the financial product are used to meet the environmental or social characteristics promoted by the Fund.

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

• Overall Global UN Compact Compliance Status.
• % of portfolio: issuers with science-based emission targets, or a verified commitments to adopt science-based emissions targets¹.
• ESG Exclusionary screens - see “G. Methodologies for environmental or social characteristics?” below for details on the exclusions.

The Sub-Investment Adviser applies screens to exclude direct investment in Prison Real Estate Investment Trusts (REITS). Companies are also excluded if they are deemed to have failed to comply with the UN Global Compact Principles.

The Sub-Investment Adviser actively engages with companies to encourage the adoption of science-based emission targets, or a verified commitment to adopt science-based emissions targets.

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

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

Where exclusions data is not available or the investment team disagrees with the assessment, the teamwork with an independent oversight body at JHI to validate the assessment.

The team’s proprietary framework relies heavily on their real estate expertise in the assessment of material issues and considers frameworks such as SASB.

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

The JHI Sustainability Risk Policy sets out the firmwide ESG Integration Principles, Sustainable Investment Principles and Baseline Exclusions applied to investee companies.

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

Janus Henderson has a Proxy Voting Committee, which is responsible for establishing positions on major voting issues and creating guidelines overseeing the voting process.

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