Status under the EU Sustainable Finance Disclosure Regulation (SFDR) - Responsible Resources Fund

Janus Henderson Fund – Responsible Resources 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) 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.

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 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 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).

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

• Carbon – Carbon footprint scope 1 and 2
• Overall UNGC Compliance Status
• % of portfolio aligned with the Fund’s sustainability themes based on internal proprietary methodology

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).

The Fund also applies the Firmwide Exclusions Policy, which includes controversial weapons, as detailed under paragraph 10.15 of the section entitled “Investment Restrictions” to the Prospectus.

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.

JHI has chosen MSCI’s ESG Manager as its primary data source for ESG (Environmental, Social and Governance) research.

Other specialist ESG Data vendors or inhouse research may also be used to complement MSCI data. For positions not covered by the external data provider, proprietary research may be used. The appropriateness of the evidence provided is assessed by an independent body at JHI.

Data coverage is directly driven by the coverage of the underlying ESG Data Provider.

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

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