Status under the EU Sustainable Finance Disclosure Regulation (SFDR) – European Growth Fund
Janus Henderson Fund – European Growth Fund
The Fund is categorised as one which meets the provisions set out in Article 8 of SFDR as a product which promotes environmental and/or social characteristics.
Binding Investment Limitations
In order to meet the environmental and/or social characteristics promoted by the Fund, the Investment Manager applies the following binding criteria to the selection of the underlying assets as part of its investment decision-making process:
The Investment Manager applies screens to exclude direct investment in issuers based on their involvement in certain activities. Specifically, issuers are excluded if they derive more than 10% of their revenue from oil sands extraction, arctic oil and gas, thermal coal extraction and power generation, palm oil, or tobacco.
The Fund also applies the Firmwide Exclusions Policy, as detailed under paragraph 10.15 of the prospectus under the section entitled “Investment Restrictions”.
The Investment Manager may invest in issuers with a high carbon intensity (other than those excluded as described above) if it determines that such issuers have a credible transition strategy, based on its proprietary methodology. A company will only be considered as having a credible transition strategy if it has at least one of the following:
- a science-based emissions target*; or
- a verified commitment to adopt a science-based emissions target*; or
- an ESG rating of AA or higher**; or
- In the specific case of the airlines sector, made significant aircraft fleet investment to reduce carbon output (that is to have a younger than average fleet age); or
- has committed 30% of future gross capex and/or research and development to sustainability aligned projects.
*approved or verified by SBT- https://sciencebasedtargets.org/ or equivalent
** rating by MSCI - https://www.msci.com/ or equivalent
Additional criteria may also be applied in assessing the validity of the transition strategy.
Furthermore, the Investment Manager carries out its review from an ESG perspective (i.e. ‘extra-financial analysis’) on at least 90% of the securities to be invested in by the Fund.
The Investment Manager may include positions in the Fund that meet the above exclusion criteria where the Investment Manager believes that the data used to apply the exclusions may be insufficient or inaccurate.
Sources of data include a wide range of specialist ESG research materials, internal and external research which includes data from data providers, industry bodies and organisations, academia, and intergovernmental organisations. Such data is integrated into the Investment Manager’s investment and risk management systems and procedures as part of the investment process.
Further information can be found in the Prospectus for the Fund.
Information on how the environmental or social characteristics are met
All investments are monitored for compliance to the above forementioned negative screening criteria to ensure that they meet the environmental and/or social characteristics promoted by the Fund.
Investors should note that a specific index is not designated as a reference benchmark to determine whether the Fund is aligned with the environmental and/or social characteristics promoted.
A description of the extent to which environmental and/or social characteristics are met will be available as part of the annual report. This information will also be published on this website once available.
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.
Principal adverse impacts - financial product disclosure
PAIs are considered at the product level.1 The table below sets out where PAI is considered through the use of exclusionary screens:
|Principal Adverse Impact||How is PAI considered?|
|GHG Emissions||Exclusionary screens|
|Carbon Footprint||Exclusionary screens|
|GHG Intensity of Investee Companies||Exclusionary screens|
|Exposure to companies active in fossil fuel||Exclusionary screens|
|Activities negatively affecting biodiversity sensitive areas||Exclusionary screens|
|Exposure to controversial weapons||Exclusionary screens|
1 This was effective as of 31 October 2022 and periodic reporting will commence from 1 January 2023 for the first reference period from 31 October 2022.