Status under the EU Sustainable Finance Disclosure Regulation (SFDR)

 

B. No Sustainable Investment Objective

This financial product promotes environmental or social characteristics and whilst it does not have as its objective a sustainable investment, it will have a minimum proportion of 10% of sustainable investments with a social objective and an environmental objective in economic activities that do not qualify as environmentally sustainable under the EU Taxonomy.

The Sub-Investment Adviser uses a pass/fail test meaning that each sustainable investment must meet all three of the requirements below:

1. it positively contributes to an environmental or social objective;
2. it does not cause significant harm to any environmental or social sustainable investment objective; and
3. it follows good governance practices.

This Fund invests a minimum of 10% of its net asset value in sustainable investments in pursuit of its investment objective. All sustainable investments will be assessed by the Sub-Investment Adviser to comply with its sustainable investment methodology.

The sustainable investments held by the Fund may contribute to addressing a range of environmental and/or social issues. An investment will be determined to make a positive contribution to an environmental or social objective where:

1. its business activity, defined as a minimum 20% of revenue, positively contributes to environmental and/or social objectives, which may include but are not limited to, alternative energy, energy efficiency, pollution prevention, nutrition, sanitation, and education; or
2. its business practices incorporate carbon emissions targets approved by the Science-Based Targets initiative (SBTi).

The Sub-Investment Adviser uses third-party data and/or proprietary analysis, including the MSCI ESG Controversies methodology, to assess the principal adverse impacts on sustainability factors as set out in table 1 of Annex I of the Commission Delegated Regulation (EU) 2022/1288 as amended from time to time. Investments considered to have negatively impacted sustainability factors and cause significant harm are not considered as sustainable investments. The MSCI ESG Controversies methodology aligns with certain principal adverse indicators to create specific exclusions related to severe controversies in areas such as pay, land use and biodiversity, water management, and toxic waste. Whilst the principal adverse indicators do not provide specific thresholds for harm they can be leveraged in identifying potentially the most significant harm.

The Sub-Investment Adviser uses third-party data and/or proprietary analysis, including the MSCI ESG Controversies methodology, to assess alignment with the OECD Guidelines for Multinational Enterprises and the UN Guiding Principles on Business and Human Rights. Investments considered to have violated these principles are not considered as sustainable investments. This framework is subject to ongoing review, particularly as the availability, and quality, of the data evolves.

C. Environmental or social characteristics of the financial product

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. In addition, the Fund invests a minimum of 10% of its net asset value in sustainable investments.

D. Investment Strategy

This Fund seeks income returns in excess of the benchmark with potential for capital growth through investment in the global markets and specifically through exposure to property related securities. 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, 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. One binding criterion - “exclude direct investment in Prison Real Estate Investment Trusts (REITS)” - is not available as automated data points and is evidenced by external or in-house research.

The exclusionary screens are implemented on both a pre- and post-trade basis enabling the Sub-Investment Adviser 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 Sub-Investment Adviser has developed a proprietary framework based on internal analysis and data from external vendors to assess securities on specific indicators relating to good governance.

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 at www.janushenderson.com/corporate/who-we-are/brighter-future-project/responsibility/esg-resources/. In addition, the Sub-Investment Adviser is a signatory to the UN-supported Principles for Responsible Investment (PRI). As a signatory, the good governance practices of are also assessed by having regard to the PRI principles prior to making an investment and periodically thereafter.

E. Proportion of investments

A minimum of 90% of the investments of the financial product are used to meet the environmental or social characteristics promoted by the Fund. In addition, the Fund invests a minimum of 10% of its net asset value in sustainable investments.

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.

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 UN Global UN Compact Compliance Status.
• % of portfolio: issuers with science-based emission targets, or a verified commitments to adopt science-based emissions targets.
• ESG Exclusionary screens – see Section G below for details on the exclusions.

The Front Office Controls & Governance team provide ongoing assurance where required, that we can evidence investment products being 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 implement exclusionary screening and monitor this on an ongoing basis in addition to elements of manual oversight where relevant.

G. Methodologies for environmental or social characteristics

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 (which cover matters including human rights, labour, corruption, and environmental pollution).

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 Sub-Investment Adviser commits to a minimum of 10% of companies within the portfolio having approved or committed targets and will monitor the progress of those companies against those targets.

Further, the Fund holds a minimum of 10% of its net asset value in sustainable investments,
The Sub-Investment Adviser uses a pass/fail test meaning that each sustainable investment must meet all three of the requirements below:

1. it positively contributes to an environmental or social objective;
2. it does not cause significant harm to any environmental or social sustainable investment objective; and
3. it follows good governance practices.

The Fund also applies the Firmwide Exclusions Policy (see “Firmwide Exclusions” in the "JHI Responsible Investment Policy”), which includes controversial weapons.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 as its primary data source for ESG (Environmental, Social, Governance) research. This helps ensure that in an effort to provide consistent data and methodologies are given an ESG measure per security type and hence enabling them to be compared correctly in the portfolio construction process.

Where coverage gaps are identified, specialist ESG Data vendors or inhouse research may be used to complement the ESG research.

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 methodology, as we recognise 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. 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.

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. The promotion of the social and environmental characteristics is not wholly dependent on third party data, any methodology limitations thereof and is typically also informed by proprietary research, engagement with investee companies where there might be relevant data gaps.

JHI’s internal data structure provides sufficient flexibility to incorporate proprietary research 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 Responsible Investment Policy sets out the firmwide approach to ESG Integration, including JHI’s Responsible Investment Principles for long-term investment success, our approaches to Stewardship and Engagement and Firmwide 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 where required, that we can evidence investment products being 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 'responsible investment policy ’ published under the ‘ESG Resource Library’ at https://www.janushenderson.com/corporate/who-we-are/brighter-future-project/responsibility/esg-resources/. 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, 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.

M. Principal adverse impacts (PAIs)

As at the 21 Nov 2025, the Investment Manager considers the following principal adverse impacts on sustainability factors (“PAIs”) for this Fund:

Adverse Sustainability Indicator		Metric	How is PAI considered
Greenhouse gas emissions	GHG Emissions	Scope 1 GHG emissions	Through engagements with companies
		Scope 2 GHG emissions	Through engagements with companies
	Carbon footprint	Carbon footprint	Through engagements with companies
	GHG Intensity of investee companies	HG intensity of investee companies	Through engagements with companies
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 screens
	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

'Where the translated version of this disclosure text differs from the English version, the original English version prevails'