Status under the EU Sustainable Finance Disclosure Regulation (SFDR)

B. No Sustainable Investment Objective

This financial product promotes environmental or social characteristics but it does not have as its objective sustainable investment.

C. Environmental or social characteristics of the financial product

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

• apply screens to exclude direct investment in securitisations and corporate credit issuers based on their involvement in certain activities. Specifically, securitisations and corporate credit issuers are excluded if they derive more than 10% of their revenue from tobacco, adult entertainment, thermal coal extraction, oil sands or artic drilling, or in the case of collateralised loan obligations, if more than 10% of their collateral balance invested in tobacco, adult entertainment, thermal coal, oil sands or artic drilling.
• apply screens to exclude direct investment in securitisations based on the involvement of key parties (the entity with most influence over the management of the collateral) in certain activities. Specifically, securitisations are excluded if the key parties (the entities with most influence over the management of the collateral) derive more than 10% of their revenue from tobacco, adult entertainment, thermal coal, oil sands or artic drilling.
• apply screens so that the Fund does not invest in securitisations where key parties (the entity with most influence over the management of the collateral) are in breach of the UNGC Principles (which cover matters including human rights, labour, corruption, and environmental pollution).
• leverage the Investment Adviser's climate transition risk assessment
• leverage a proprietary ESG framework, utilising both third party data and s . proprietary insights, to produce securitisation issuer ratings. To encourage the adoption of better environmental and/or social practices the Fund will only invest in the top 5 of the 6 ratings.
• leverage a proprietary ESG framework, utilising both third party data and proprietary insights, to categorise corporate credit issuers against six ratings. To encourage the adoption of better environmental and/or social practices the Fund will only invest in the top 5 of 6 category ratings.

 

D. Investment Strategy

The binding elements of the investment strategy described below, that are implemented as screens are coded into the compliance module of the Investment Advisers’ 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 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 Investment Adviser to follow good governance practices. The 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 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 at https://www.janushenderson.com/corporate/who-we-are/brighter-future-project/responsibility/esg-resources/

In addition, the Investment Adviser is a signatory to the UN-supported Principles for Responsible Investment (PRI). As a signatory, the good governance practices of investee companies are also assessed by having regard to the PRI prior to making an investment and periodically thereafter.

E. Proportion of investments

A minimum of 70% of the investments of the financial product are used to meet the environmental or social characteristics promoted by the financial product. Other assets, which are not used to meet the environmental or social characteristics 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

• ESG Exclusionary screens – see “What are the binding elements of the investment strategy used to select the investments to attain each of the environmental or social characteristics promoted by this financial product?” below for details on the exclusions.
• Overall UNGC Principles Compliance Status.
• Ratings of securitisation issuers across the portfolio based on the proprietary framework.
• Ratings of corporate issuers across the portfolio based on the proprietary framework.
• Number of companies engaged with in line with the Investment Adviser’s engagement approach

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.

ESG Exclusionary screens – see Section G below for details on the exclusions.

Data Sources and processing – as further described under Section H

G. Methodologies for environmental or social characteristics

The Investment Adviser uses specific screens to help achieve some of the promoted characteristics. For example- to promote climate change mitigation, screens are applied to avoid investment in certain high carbon activities, and it is expected that this will result in the fund having a lower carbon profile. Another example is that to promote support for the UNGC Principles, screens are applied so that the Fund does not invest in issuers that are in breach of the UNGC and OECD MNE Principles based on third party data and/or internal research.

The Investment Adviser applies screens to exclude issuers if they are deemed to have failed to comply with the UNGC and OECD MNE Principles (which cover matters including human rights, labour, corruption, and environmental pollution).

In addition, the Investment Adviser applies screens to exclude direct investment in corporate issuers based on their involvement in certain activities. Specifically, issuers are excluded if they derive any revenue from controversial weapons*, oil sands extraction, thermal coal extraction, Arctic oil and gas extraction, tobacco and adult entertainment.

*the Fund applies enhanced controversial weapon screening in addition to the firmwide exclusions which screen a broader range of activities

The Fund also applies the Firmwide Exclusions Policy (the “Firmwide Exclusions Policy”), which includes controversial weapons:

The Investment Adviser assesses each company held by the Fund in relation to its impact on the environment and society in addition to an analysis of the governance risks it exhibits.

The Investment Adviser may only invest in companies that would be excluded by the screens described above if the Investment Adviser believes, based on its own research and as approved by its ESG Oversight Committee, that the third-party data used to apply the exclusions is insufficient or inaccurate.

The Investment Adviser may consider that the data is insufficient or inaccurate if, for example, the third-party data provider research is historic, vague, based on out-of-date sources, or the Investment Adviser has other information to make them doubt the accuracy of the research.

If the Investment Adviser wishes to challenge the third-party data, then the challenge is presented to a cross-functional ESG Oversight Committee who must sign off on the “override” of the third-party data.

If a third-party data provider does not provide research on a specific issuer or excluded activity, the Investment Adviser may invest if, through its own research, it is satisfied that the issuer is not involved in the excluded activity.

H. Data sources and processing

The Fund has chosen MSCI 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 in an effort to provide consistent data and methodologies per security type and hence, enabling them to 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 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, or 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, which incorporates JHI’s Sustainability Risk 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 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 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’ on the Janus Henderson website 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, 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.

M. Principal Adverse Impacts (PAI)

As at the 28 August 2025, the Investment Adviser 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	Exclusionary screen
		Scope 2 GHG emissions	Exclusionary screen
	Carbon footprint	Carbon footprint	Exclusionary screen
	GHG Intensity of investee companies	HG intensity of investee companies	Exclusionary screen
	Exposure to companies active in the fossil fuel sector	Share of investments in companies active in the fossil fuel sector	Exclusionary screen
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