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Status under the EU Sustainable Finance Disclosure Regulation (SFDR) – Global Equity Market Neutral Fund

Janus Henderson Fund – Global Equity Market Neutral 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 social characteristics promoted by the Fund, the Investment Manager applies binding criteria to the selection of underlying assets as part of its investment decision making process.

The Investment Manager applies screens to long positions in the Fund 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 or power generation. Issuers are also excluded if they are deemed to have failed to comply with the UN Global Compact Principles (which cover matters including human rights, labour, corruption, and environmental pollution).

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 also applies screens to exclude companies which have an ESG rating of B or lower*.

* rating from MSCI - https://www.msci.com/ or equivalent

The Investment Manager may include positions in the Fund that meet the above exclusionary criteria where the Investment Manager believes that the data used to apply the exclusions is insufficient or inaccurate.

The Investment Manager carries out its review from an ESG perspective (i.e. ‘extra-financial analysis’) on at least 90% of the long positions.

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.

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.

Periodic Reports

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 not considered for this product.

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