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 15% 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 Manager 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 Sub-Fund invests a minimum of 15% of its net asset value in sustainable investments. All sustainable investments will be assessed by the Sub-Investment Manager 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 include 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).

Sustainable investments meet the do no significant harm requirements, as defined by applicable law and regulation. Investments considered to be causing significant harm do not qualify as sustainable investments. The Sub-Investment Manager identifies investments which negatively impact sustainability factors and cause significant harm by using third-party data and/or analysis, including the MSCI ESG Controversies methodology. However, assessment of adverse impacts is not wholly dependent on third-party data, or any methodology limitations thereof.

The Sub-Investment Manager has chosen MSCI as its primary source for ESG data and research. Where coverage gaps are identified, specialist ESG data vendors or the Sub-Investment Manager’s proprietary research (including engagement with investee companies, where relevant) may be used to complement it. Portfolio managers may challenge third-party data if they consider that it is insufficient or inaccurate (if, for example, it is historic, vague, based on out-of-date sources) or if they have other information to make them doubt its accuracy. Any “override” of third-party data must be approved by the Sub-Investment Manager’s cross-functional ESG Oversight Committee.

The Sub-Investment Manager uses third-party data and/or analysis proprietary to the Sub-Investment Manager, 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, which is designed to identify companies that may have caused or contributed to negative environmental or social impacts, aligns with certain principal adverse impact indicators and is used to create specific exclusions in relation to those indicators. Whilst the principal adverse impact indicators do not provide specific thresholds for harm, they can be leveraged in identifying potentially the most significant harm. Further information on the MSCI ESG Controversies methodology can be found at https://www.msci.com/.

The Sub-Investment Manager uses third-party data, including the MSCI ESG Controversies methodology, and/or its own proprietary analysis, 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. Investments are monitored daily and those deemed to have violated these principles are not considered 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 Sub-Fund promotes support for the UN Global Compact principles (which cover matters including human rights, labor, corruption, and environmental pollution).

The Sub-Fund promotes better management of environmental, social and/or governance (ESG) risks by minimising its exposure to issuers with the worst ESG risk ratings, i.e. those rated below BB by MSCI or equivalent, and by engaging with issuers who are considered ESG laggards (rated below BB by MSCI or equivalent). Companies with the worst ESG risk ratings demonstrate a higher exposure to ESG risks / worse management of ESG risks compared to companies with better ESG risk ratings.

The Sub-Fund also promotes human health and wellbeing and climate change mitigation by applying binding exclusions seeking to avoid investments in certain activities.

In addition, the Sub-Fund invests a minimum of 15% of its net asset value in sustainable investments. The Sub-Fund does not use a reference benchmark to attain its environmental or social characteristics.

D. Investment Strategy

The Sub-Fund aims to outperform its Index Benchmark (MSCI World Index) over the long term by investing in an actively managed portfolio of equity securities and/or depositary receipts issued by global companies. This may include investing up to 15% of the Sub-Fund’s assets in equity securities and/or depositary receipts of emerging market companies.

The Sub-Investment Managers select and weight securities using the research and recommendations of the Sub-Investment Manager’s equity analysts, some quantitative inputs, and ESG exclusions and constraints (as described in this document). The portfolio is constructed so as to emphasise stock selection and minimise unintended risks. The resulting portfolio will typically have between 125 and 275 holdings. The Sub-Investment Manager will also seek to manage the Sub-Fund’s risk profile relative to the Index Benchmark.

Investors should read this section in conjunction with the Sub-Fund’s investment strategy (as set out in the supplement for the Sub-Fund under the heading “Investment Objective and Policy”). The binding elements of the investment strategy described below that are implemented as screens 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.

The companies in which investments are made are assessed by the Sub-Investment Manager to follow good governance practices. The Sub-Investment Manager has developed a proprietary framework to assess good governance that is 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 Manager 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 http://www.janushenderson.com/corporate/who-we-are/brighter-future-project/responsibility/esg-resources.

In addition, the Sub-Investment Manager 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 80% of the investments of the financial product are used to meet the environmental or social characteristics promoted by the Sub-Fund. In addition, the Sub-Fund invests a minimum of 15% of its net asset value in sustainable investments.

The remaining investments, which are not used to meet the environmental or social characteristics, relate to cash held as ancillary liquidity and 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:

• Number of companies in the Sub-Fund’s portfolio with a UNGC status of “fail” (expected to be 0%)
• Proportion of the portfolio invested in issuers with an ESG rating of BB or above by MSCI ESG or equivalent (expected to be at least 80% of portfolio)
• Proportion of the portfolio subject to engagement (expect to be 100% of the portion of the portfolio invested in companies that are (i) rated below BB by MSCI ESG or equivalent and (ii) have a weighting of 0.3% or greater in the Sub-Fund’s portfolio)
• ESG Exclusionary screens - see “G. Methodologies for environmental or social characteristics?” 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 Manager will:

• Apply screens to exclude companies with a UNGC status of “fail”
• Apply screens to ensure that, of the portfolio invested in corporate issuers of equities, at least 80% have an ESG risk rating of BB or higher (by MSCI – https://www.msci.com/, or equivalent).
• Consider companies with a MSCI ESG risk rating of B or CCC to be ESG laggards. It will engage with such issuers where the weighting of the issuer in the portfolio is greater than or equal to 0.3%.
• Apply screens to exclude companies with 10% or more revenue generated from thermal coal and tobacco.

The Sub-Fund holds a minimum of 15% of its net asset value in sustainable investments, as outlined in more detail in the section “What are the objectives of the sustainable investments that the financial product partially intends to make and how does the sustainable investment contribute to such objectives?”

The Sub-Fund also applies the Firmwide Exclusions Policy (see “Firmwide Exclusions” in the "JHI Responsible Investment Policy”), which includes controversial weapons.

The Sub-Investment Manager may only invest in companies that would be excluded by the screens described above if the Sub-Investment Manager 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 Sub-Investment Manager 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 Sub-Investment Manager has other information to make them doubt the accuracy of the research.

If the Sub-Investment Manager 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 Sub-Investment Manager may invest if, through its own research, it is satisfied that the issuer is not involved in the excluded activities.

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, 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.

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 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.

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 (PAIs)

As at 21 October 2025, the Sub-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	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