For institutional investors in the Netherlands

EU Sustainable Finance Disclosure

The investments underlying this financial product do not take into account the EU criteria for environmentally sustainable economic activities, although the Investment Manager has a decision making process that applies to investment decisions relating to this financial product as further detailed in applicable pre-contractual disclosures.

While the analysis of ESG factors is an integral component across the Investment Manager’s investment capabilities and one of a number of inputs to the selection of investments and portfolio construction, the investment process of the Investment Manager is primarily designed to maximise long-term risk-adjusted returns for investors. Therefore, in managing the Portfolio, the Investment Manager does not maximise portfolio alignment with sustainability risks as a separate goal in its own right nor does it precisely attribute the impact of ESG factors on returns for the Portfolio.

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”). Henderson Management S.A. (“HMSA”) is a member of the Janus Henderson group incorporated in Luxembourg and is subject to SFDR as a financial market participant.

HMSA 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 HMSA’s activities, HMSA has decided not to comply with the PAI Regime at the current time. Nonetheless, HMSA wishes to affirm its overall commitment to ESG matters. As part of this commitment, HMSA 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.

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