Status under the EU Sustainable Finance Disclosure Regulation (SFDR) – Janus Henderson Horizon Biotechnology Fund

Janus Henderson Horizon Biotechnology Fund

The Fund is categorised as one which meets the disclosure 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.

A. Summary

The Fund promotes the following environmental and/or social characteristics: -

• Minimising exposure to corporate issuers with the worst ESG ratings.
• 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.

This Fund seeks long-term growth of capital by investing in equities (also known as company shares) of biotechnology and biotechnology-related companies.

Investors should read this section in conjunction with the Fund’s investment strategy (as set out in the supplement for the Fund under the heading “Investment Objective and Policies”).

The binding elements of the investment strategy described below that are implemented as screens which are coded into the compliance module of an 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 any proposed transactions in an excluded security to be blocked and to identify any changes to the status of holdings when third-party data is periodically updated.

Engagement plans are agreed and periodically reviewed for engagement activity including progress against the engagement plan during the 24-month period.

The Investment Manager will, based on ratings by MSCI – https://www.msci.com/, or equivalent:

• Apply screens to ensure at least 80% of the portfolio is invested in corporate issuers with an ESG risk rating of BB or higher.
• Engage with issuers in breach of UNGC principles and will only invest or continue to be invested if it considers through such engagement that they are on track to improve. If the issuer does not achieve a “pass” rating within 24 months, it will divest, and screens will be applied to exclude the issuer.

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

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

a. 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.

b. 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 include positions in the Fund that, based on third-party data or screens, appear to fail the above criteria, where the Investment Manager believes that the third- party data may be insufficient or inaccurate.

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 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 ESG 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.