PAI Corporate Statement

Principal adverse impacts ("PAI")

The EU’s Sustainable Finance Disclosure Regulation (“SFDR”) requires financial market participants to make a ‘comply or explain’ decision as to whether they consider principal adverse impacts (“PAIs”) of investment decisions on sustainability factors in accordance with a specific regime outlined in SFDR (the “PAI Regime”). Janus Henderson Investors Europe S.A. (“JHIESA”) is a member of the Janus Henderson group incorporated in Luxembourg and is subject to SFDR as a financial market participant.

JHIESA is supportive of the general policy aims of the PAI Regime, to improve transparency to clients, investors and the market, as to how financial market participants integrate consideration of the adverse impacts of investment decisions on sustainability factors. Taking into account the size, nature and scale of JHIESA’s activities, JHIESA has decided not to comply with the PAI Regime at the current time. Nonetheless, JHIESA wishes to affirm its overall commitment to ESG matters. As part of this commitment, JHIESA currently manages products that are classified under either Article 8 or Article 9 of SFDR. More information on Janus Henderson’s overall commitment to ESG matters is also described in our ESG overview

JHIESA will keep its decision not to comply with the PAI Regime under regular review.