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Status under the EU Sustainable Finance Disclosure Regulation (SFDR) – Global Life Sciences Fund

Janus Henderson – Global Life Sciences 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 and invests in companies with good governance practices.

A. Summary

This financial product promotes environmental or social characteristics and invests in companies with good governance practice but does not have as its objective sustainable investment

The Fund promotes support for the United Nations Global Compact principles (which cover matters including human rights, labour, corruption, and environmental pollution), and avoids issuers with the worst ESG risk ratings.

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 on covered securities, which are coded into the compliance module of 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”).

The Sub-Investment Adviser applies screens based on third party data and/or internal research to exclude companies 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 Sub-Investment Adviser applies screens to ensure at least 80% of the portfolio is invested in companies with an ESG risk rating of BB or higher (by MSCI – https://www.msci.com/, or equivalent).

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

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 the ESG Oversight Committee (ESG OC) .

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

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

B. No Sustainable Investment Objective

This financial product promotes environmental or social characteristics but does not have as its objective sustainable investment and invests in companies with good governance practices

C. Environmental or social characteristics of the financial product

The Fund promotes support for the UN Global Compact principles (which cover matters including human rights, labour, corruption, and environmental pollution), and avoids issuers with the worst ESG risk ratings.

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

D. Investment Strategy

This Fund seeks long-term growth of capital by investing at least 80% of its net asset value in equities (also known as company shares) located anywhere in the world and selected for their growth potential and which the relevant Sub-Investment Adviser believes have a life sciences orientation. Generally speaking, the “life sciences” relate to maintaining or improving quality of life.

The Fund is Actively Managed with reference to the MSCI World Health Care Index, which is broadly representative of the companies in which it may invest. The Sub-Investment Adviser generally takes a “bottom-up” approach to building portfolios.. The Fund follows an investment strategy in which companies are considered principally on their own fundamental qualitative and quantitative characteristics. Commonly referred to as stock picking or bottom-up investing, portfolios of fundamental-based investment funds are built one security at a time following intensive in-house research into each company. This approach rests on a belief that some companies have inherent strengths for creating shareholder value over time, have superior prospects to their peer groups and should therefore outperform even in challenging industry and economic circumstances. The purpose of a fundamental investment approach is to identify and invest in such 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 are implemented as exclusionary screens on covered securities, which are coded into the compliance module of the Sub-Investment Adviser’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 companies in which investments are made are assessed by the Sub-Investment Adviser 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 Sustainability Risk Policy (“Policy”).

The Policy sets minimum standards against which investee companies will be assessed and monitored by the Sub-Investment Adviser 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 Policy can be found incorporated within Janus Henderson’s “ESG Investment Policy” in the “About Us – Environmental, Social and Governance (ESG)” section of the website at www.janushenderson.com.

In addition, the Sub-Investment Adviser 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.

E. Proportion of investments

A minimum of 80% of the investments of the financial product are used to meet the environmental or social characteristics promoted by the Fund.

Other assets, which are not used to meet the environmental or social characteristics, may include cash or cash equivalents, investments in private equity, in addition to instruments held for the purposes of efficient portfolio management and/or investment purposes e.g., temporary holdings of index derivatives.

F. Monitoring of environmental or social characteristics

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 the Fund
  • At least 80% of the Fund’s portfolio will be invested in issuers with an ESG rating of BB or above by MSCI or equivalent.

G. Methodologies for environmental or social characteristics

The Sub-Investment Adviser uses specific screens to help achieve some of the promoted characteristics. For example- the Sub-Investment Adviser applies screens based on third party data and/or internal research to exclude companies 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 Sub-Investment Adviser applies screens to ensure at least 80% of the portfolio is invested in companies with an ESG risk rating of BB or higher (by MSCI – https://www.msci.com/, or equivalent).

The Fund also applies the Firmwide Exclusions Policy , which includes controversial weapons:

This applies to all the investment decisions made by the Management Company or Sub-Investment Adviser. The Firmwide Exclusions Policy may be updated from time to time.

Presently, investment is not permitted in entities involved in the current manufacture of, or minority shareholding of 20% or greater in a manufacturer of controversial weapons, namely:

  • Cluster munitions;
  • Anti-Personnel mines;
  • Chemical weapons;
  • Biological weapons.

Classification of issuers is primarily based on activity identification fields supplied by our third-party ESG data providers. This classification is subject to an investment research override in cases where sufficient evidence exists that the third-party data field is not accurate or appropriate. In any scenario where a portfolio position is identified as not meeting this exclusion criteria for any reason (legacy holding, transition holding, etc.) the Sub-Investment Adviser shall be granted 90 days to review or challenge the classification of the issuer if appropriate. After this period, in the event an investment research override is not granted divestment is required immediately under normal market trading circumstances.

For the purposes of the AMF doctrine, the extra-financial analysis or rating 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 Sub-Investment Adviser may include positions in the Fund that, based on third-party data or screens, appear to fail the above criteria, where the Sub-Investment Adviser believes that the third- party data may be insufficient or inaccurate.

H. Data sources and processing

The Fund has chosen MSCI’s ESG Manager 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 consistent data and methodologies are used given an ESG measure per security type and hence can be compared correctly in the portfolio construction process.

JHI has built a centralised proprietary research alignment process; The central research alignment process aligns data at three different levels

      1. Entity Level,
      2. Position Level, and
      3. Fund Level.

The research alignment and mapping capability is critical to JHI's ESG (Environmental, Social and Governance) methodology, as we recognize a security could inherit the ESG information from the issuing legal entity, however, some ESG risks will be instrument specific.

JHI applies a series of Data Quality rules to ensure the integrity of the data being ingested into the central research alignment solution. JHI data that is not aligned correctly to the definition as provided by the data vendor is not ingested into the central cloud-based data warehouse and exceptions are raised. These exceptions are monitored and remediated by a central support team. Remediation includes challenging the data provider or internal operations supporting internally managed Systems of Records. Where appropriate the Data Owner responsible and accountable for the data is notified through the internal Data Governance process to resolve outstanding exceptions.

JHI receives weekly automated data feeds from external ESG Data vendors, which are ingested into a cloud-based data warehouse. Once the data is ingested and Data Quality checks have been performed the raw data is mapped to JHI’s internal taxonomy structure. This ensures that all ESG data from the data warehouse is made available consistently across all downstream JHI applications supporting the different stages in the investment process.

The proportion of data for a Financial Product that is estimated is constantly evolving.

Some data used to support binding criteria as received from external providers may be estimated data. For positions not covered by the external data provider, proprietary research may be used. This could range from proprietary research alignment against the external data vendor to written confirmation from the issuing entity that it aligns to the binding criteria. The appropriateness of the evidence provided is assessed by an independent body at JHI.

I. Limitations to methodologies and data

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.

JHI is aware of data gaps in ESG Research for non-traditional asset classes compared to mainstream asset classes such as equities and debt instruments.

J. Due diligence

The JHI Sustainability Risk Policy sets out the firmwide ESG Integration Principles, Sustainable Investment Principles 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 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 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 ensure that ESG-related activities are managed in line with regulatory requirements and expectations and considered within our compliance framework.

K. Engagement Policies

In addition to the binding elements of the investment strategy described above, 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 ‘ESG Investment Policy’ published under the ‘ESG Resource Library’ on the Janus Henderson website.

The Firm supports a number of stewardship codes and broader initiatives around the world and is a signatory to the UK stewardship code.

Janus Henderson has a Proxy Voting Committee, which is responsible for establishing positions on major voting issues and creating guidelines overseeing the voting process. The Committee is comprised of representatives of investments portfolio management, corporate governance, accounting, legal and compliance. Additionally, the Proxy Voting Committee is responsible for monitoring and resolving conflicts of interest with respect to proxy voting.

L. Designated Reference Benchmark

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

Principal adverse impacts (PAI)

As at 11 September 2023 , PAIs are considered at the product level. The table below sets out where PAI is considered through the use of exclusionary screens:

Adverse Sustainability Indicator

Metric

How is PAI considered

Social and Employee matters Share of investments in investee companies involved in the manufacture or selling of controversial weapons Exposure to controversial weapons (anti-personnel mines, cluster munitions, chemical weapons and biological weapons) Exclusionary screen
Violations of UN Global Compact principles and Organisation for Economic Cooperation and Development (OECD) Guidelines for Multinational Enterprises Share of investments in investee companies that have been involved in violations of the UNGC principles or OECD Guidelines for Multinational Enterprises Exclusionary screen Share of investments in investee companies that have been involved in violations of the UNGC principles or OECD Guidelines for Multinational Enterprises Exclusionary screen
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