ATLAS Global Infrastructure Fund

Sustainable, Responsible &/or ESG Policy:

Background to ESG at ATLAS

ATLAS believes that over the long-term, all infrastructure assets operate under an implicit Environmental, Social and Governance ‘contract’ with customers, regulators and wider stakeholders. This contract will influence their ability to generate long-term returns in the same way as any formal contracts they may have. Further, we recognise that due to their long duration, infrastructure assets are particularly susceptible to the inevitable policy response to environmental change.

For our investors and for our staff, responsible investment is one of the most important issues of our age: our clients and our team both expect that responsibility should be part of the core ethos of our firm. 

Recognising this, responsible investment is embedded in every level of our investment process, starting at the company level. 

Key ESG Priorities

The Fund's key ESG priorities are:

• climate change and energy transition;
• monitoring the social contract between infrastructure companies and their customers, regulators and the wider public; and
• monitoring the governance and management remuneration of companies in our universe.

ATLAS seeks to maintain a strong focus on ESG issues as they affect infrastructure investment, particularly with respect to climate change and energy transition. We frequently refine and upgrade our analysis and assumptions in the light of new data, legislation or policy assumptions and we work with our specialist external advisors on our Investment Governance Board and our Macro Advisory Board to ensure that we remain abreast of all such developments.

Level of ESG integration:

Firm-Level ESG Integration

ATLAS has embedded ESG considerations into its governance, culture and investment processes. ESG is not managed by a separate specialist team; rather, responsibility sits directly with the investment team to ensure ESG considerations form part of all research and investment decisions. The firm maintains formal ESG governance structures, uses external ESG data alongside proprietary analysis, participates in industry initiatives, and seeks to ensure that corporate culture and incentives support sustainable investment outcomes.

Stock and Asset-Level Research, Engagement and Voting

ESG analysis is integrated into fundamental company research and investment due diligence. Analysts assess environmental, social and governance risks and opportunities at the individual company and asset level, incorporating findings into financial modelling, cash flow forecasts, scenario analysis and stress testing. ATLAS actively engages with management teams and boards on material ESG issues and incorporates ESG considerations into proxy voting recommendations. Voting and engagement activities are used to encourage responsible corporate behaviour and support long-term value creation.

Portfolio-Level Risk Management and Construction

The insights generated through company-level ESG research are aggregated and incorporated into portfolio construction, risk monitoring and investment decision-making. ESG factors influence expected return assumptions, scenario analysis, stress testing and portfolio risk assessments, including climate-related considerations. ESG risks identified during the research process are monitored on an ongoing basis to ensure portfolio outcomes remain aligned with investment objectives and sustainability considerations.

Reporting and Client Engagement

ATLAS provides investors with transparency on ESG integration, portfolio sustainability characteristics, climate-related metrics, stewardship activities, engagement outcomes and proxy voting records through regular reporting. The firm's ESG analysis and monitoring framework enables detailed client reporting and supports ongoing dialogue with investors regarding ESG risks, opportunities and portfolio outcomes.

Process:

We have incorporated Responsible Investment (“RI”) objectives through developing an ESG implementation framework that covers measurement, investment decision making and engagement with company management.  There are a number of elements to this process, whereby ATLAS:

• considers the implications of each ESG factor at an individual portfolio company level and takes these factors into account through its modelling and the impacts of those factors on the portfolio companies' cash flows and asset stress testing. This includes the use of external ESG data providers to complement their internal process and analysis.
• uses the results of the company level ESG due diligence in order to make portfolio investment decisions and to monitor and report ongoing portfolio risk to investors.
• uses the ESG analysis to actively engage with portfolio companies to promote responsible and sustainable decision making by company management teams.
• establishes formal ESG governance structures and responsibilities to monitor the incorporation of ESG in the investment process and ensure that the portfolio outcomes are consistent with the sustainable objectives of the portfolio as well as consistent with the managers commitments under the Net Zero Asset Managers’ (“NZAM”) initiative
• is an active member of industry groups and bodies that support ESG outcomes.
• ensures that our corporate culture and incentives promote the ESG outcomes of the portfolio.

 Our investment process incorporates each of the ESG factors as follows:

• Environmental: We divide environmental influences into two categories: environmental performance and climate change.  Environmental performance is monitored through company and regulatory disclosures, and we reflect that performance within the cash flows of our company models.  Climate change is a particular focus of the company analysis and we have separately outlined our approach in this response (Fast Transition analysis), given the importance of this particular factor.
• Social: ATLAS recognises that infrastructure assets operate under an implicit social contract and that companies which fail to perform in line with that contract (through overcharging, or under-delivering) may be subject to penalties or reduced allowed returns.  ATLAS’s financial models make explicit assumptions about the level of profits that can be earned by infrastructure assets and our forecasts assume that companies earn “fair” returns over time, provided that the company provides a service in line with customer and regulator expectations. 
• Governance: Governance is considered on multiple levels. In evaluating the impact of the company’s management and oversight we make specific assumptions around management’s ability to generate (or undermine) the company’s value over time.

ATLAS integrates RI directly into its investment philosophy and investment process rather than operating a standalone ESG team. Governance and oversight are provided through a tiered structure comprising the Board, Executive Committee, Investment Governance Board (IGB), Investment Committee and Investment Team.

• ATLAS Board: Provides ultimate oversight and ensures that RI and investment process policies are being followed by the investment function through its review of reports from the Investment Team and the IGB, including ESG-related matters.
• Investment Governance Board (IGB): Provides independent oversight of the investment process and outcomes, focusing on consistency with stated investment strategies and monitoring matters including ESG considerations and climate risks.
• Head of Investments: Responsible for implementation and monitoring of ESG and RI policies and objectives across the investment function.
• Investment Team and Sector Specialists: Responsible for incorporating ESG considerations into company research, valuation, risk assessment and engagement activities. ATLAS does not employ dedicated ESG/RI analysts, as it believes ESG analysis is an integral component of security analysis rather than a separate function. All investment professionals are therefore responsible for identifying and assessing ESG risks and opportunities.
• Investment Committee (IC): Responsible for portfolio construction, security selection, trade approvals, stewardship activities, proxy voting decisions and ongoing monitoring of portfolio risks, including ESG-related risks.
• Risk & Compliance Committee: Monitors ESG-related regulatory and risk management matters and reports to the Executive Committee.

ATLAS complements its internal expertise with a range of external resources, industry initiatives and specialist advisory bodies:

• External ESG data providers are used to support company level ESG analysis, monitoring and reporting.
• ATLAS incorporates the principles and guidance of the PRI, TCFD and SBTi into its responsible investment framework and climate-related analysis.
• The firm maintains a Climate Advisory Board (CAB) and Macro Advisory Board (MAB), which provide insight into climate, policy and macroeconomic developments relevant to infrastructure investing.

The members of the Macro and Climate Advisory Boards are selected to provide expertise in different regions and disciplines. They are:

• Geoffrey Warren:Geoffrey is an Associate Professor at the Australian National University, who brings with him experience of economic strategy in both commercial and academic roles. His input at the MAB focusses on Australian and global trends.
• Chris Watling:Chris is the CEO and Chief Market Strategist of Longview Economics, which he founded in 2003 following a career at Cazenove and KPMG. With a strong background in economic and scenario modelling, his geographic focus at MAB is on Europe and the US.
• Amandine Denis-Ryan:Amandine is the Head of System Change and Capability at Climate Works Australia; the leading climate change think tank in Australia.
• Nate Aden:Nate leads the Science Based Targets initiative’s work with financial institutions. He has been with SBTi since 2015 and has contributed to the technical foundations of the initiative.
• Alex Edmans:Alex is Professor of Finance at London Business School and a former tenured professor at Wharton. He has a PhD from MIT and previously worked at Morgan Stanley. Alex advises on sustainable investing and serves on multiple advisory boards. He is a Fellow of the British Academy and author of several acclaimed books on corporate finance and responsible business.
• Investment professionals attend external conferences and industry forums organised by organisations such as the IIGCC, AIMA, investment consultants and other industry participants. Insights gained from these events are shared internally and incorporated into the firm's research discussions.

ATLAS also devotes significant internal resources to ESG and RI capability development through its weekly Research Meeting, where investment views, company research and ESG-related issues are peer reviewed and debated across the investment team.

Resources, Affiliations & Corporate Strategies:

ATLAS integrates RI directly into its investment philosophy and investment process rather than operating a standalone ESG team. Governance and oversight are provided through a tiered structure comprising the Board, Executive Committee, Investment Governance Board (IGB), Investment Committee and Investment Team.

• ATLAS Board: Provides ultimate oversight and ensures that RI and investment process policies are being followed by the investment function through its review of reports from the Investment Team and the IGB, including ESG-related matters.
• Investment Governance Board (IGB): Provides independent oversight of the investment process and outcomes, focusing on consistency with stated investment strategies and monitoring matters including ESG considerations and climate risks.
• Head of Investments: Responsible for implementation and monitoring of ESG and RI policies and objectives across the investment function.
• Investment Team and Sector Specialists: Responsible for incorporating ESG considerations into company research, valuation, risk assessment and engagement activities. ATLAS does not employ dedicated ESG/RI analysts, as it believes ESG analysis is an integral component of security analysis rather than a separate function. All investment professionals are therefore responsible for identifying and assessing ESG risks and opportunities.
• Investment Committee (IC): Responsible for portfolio construction, security selection, trade approvals, stewardship activities, proxy voting decisions and ongoing monitoring of portfolio risks, including ESG-related risks.
• Risk & Compliance Committee: Monitors ESG-related regulatory and risk management matters and reports to the Executive Committee.

ATLAS complements its internal expertise with a range of external resources, industry initiatives and specialist advisory bodies:

• External ESG data providers are used to support company level ESG analysis, monitoring and reporting.
• ATLAS incorporates the principles and guidance of the PRI, TCFD and SBTi into its responsible investment framework and climate-related analysis.
• The firm maintains a Climate Advisory Board (CAB) and Macro Advisory Board (MAB), which provide insight into climate, policy and macroeconomic developments relevant to infrastructure investing.

The members of the Macro and Climate Advisory Boards are selected to provide expertise in different regions and disciplines. They are:

• Geoffrey Warren:Geoffrey is an Associate Professor at the Australian National University, who brings with him experience of economic strategy in both commercial and academic roles. His input at the MAB focusses on Australian and global trends.
• Chris Watling:Chris is the CEO and Chief Market Strategist of Longview Economics, which he founded in 2003 following a career at Cazenove and KPMG. With a strong background in economic and scenario modelling, his geographic focus at MAB is on Europe and the US.
• Amandine Denis-Ryan:Amandine is the Head of System Change and Capability at Climate Works Australia; the leading climate change think tank in Australia.
• Nate Aden:Nate leads the Science Based Targets initiative’s work with financial institutions. He has been with SBTi since 2015 and has contributed to the technical foundations of the initiative.
• Alex Edmans:Alex is Professor of Finance at London Business School and a former tenured professor at Wharton. He has a PhD from MIT and previously worked at Morgan Stanley. Alex advises on sustainable investing and serves on multiple advisory boards. He is a Fellow of the British Academy and author of several acclaimed books on corporate finance and responsible business.
• Investment professionals attend external conferences and industry forums organised by organisations such as the IIGCC, AIMA, investment consultants and other industry participants. Insights gained from these events are shared internally and incorporated into the firm's research discussions.

ATLAS also devotes significant internal resources to ESG and RI capability development through its weekly Research Meeting, where investment views, company research and ESG-related issues are peer reviewed and debated across the investment team.

ATLAS is a member of several organisations that promote sustainable investing and transparency including:

UN PRI signatory

ATLAS is a signatory to the Principles of Responsible Investment (PRI), policies and processes from which have been incorporated into the ATLAS Investment Process.

Net Zero Asset Manager Alliance (NZAM)

ATLAS became a founding signatory to the Net Zero Asset Managers commitment in December 2020.  We believe this is an important commitment as it entails a tangible set of goals for the asset management community that go beyond other general statements of intent. Following the NZAM 2026 re-launch, ATLAS is reviewing its existing construction guidelines and firm commitments. Whilst still ongoing, we would expect the following as likely outcomes:

We are very likely to retain our existing investment approach including

• Company level emissions forecasting and due diligence
• alignment assessment
• portfolio construction guidelines and current 2030 targets

We are very likely to make the following changes to commitments and targets

• remove a specific date (2050) for net zero for the portfolio
• review and potentially extend the 2030 target for 100% portfolio alignment

In addition, we are expecting to update our methodology and calculations as follows:

• For emissions pathway benchmarking – evaluate companies using both a 2019 absolute baseline as well a FY1 to FY11 rolling target
• For alignment classification, we will look to set regional, country and sub regional benchmarks based on local political environment and support
• We will retain B2DS as primary but also evaluate other likely emission pathways as relevant benchmarks

FRC Stewardship Code 2020

ATLAS is a signatory to the FRC Stewardship Code.  Its most recent published Stewardship Report for the 2025 year has been approved by the FRC and will submit its report for the 2026 year by end of April 27 (see attached the Stewardship Code 2025).

Institutional Investor Group on Climate Change (IIGCC)

ATLAS has been a member of IIGCC since 2018, which is a partner organisation to the Climate Action 100+. As an active member of the IIGCC, ATLAS is part of the Investor Practices Program, and a member of the Working Group for the Paris Aligned Investment Initiative.  Based on our business aims for RI we will continue to monitor available initiatives and support those which are consistent with our views on ESG and CSR.

During 2025, ATLAS was an active member of the IIGCC’s Renewable Energy and Physical Risk Working Groups which sought to further enhance the guidance provided to the IIGCC members on these two topics.

ATLAS also engaged on a number of occasions with the IIGCC and the Net Zero Asset Managers team around the proposed path forward for the NZAM framework. This process followed the withdrawal of several high-profile NZAM signatories due in large part to changes in the regulatory / legal environment in the US and the threat of litigation over these types of joint commitments. See above for the likely outcomes of our NZAM commitments following the 2026 re-launch. 

ATLAS is a 2026 member of the IIGCC’s Infrastructure Working Group.

CA100+

In 2023 ATLAS commenced its membership of the CA100+.  This reflected the expansion of the scope of the CA100 to include a larger number of companies that are within the ATLAS investment universe.  ATLAS has already undertaken a joint engagement through CA100+.

CERES

ATLAS became a signatory to the CERES investor network on climate risk and sustainability early in 2022. CERES is the leading organisation in North America for coordinating investor, corporate, and policy action on climate change. CERES is linked with the IIGCC in Europe, with whom ATLAS originally started engaging as founding signatories of the Paris Aligned Investment Initiative and Net Zero Asset Managers initiative. ATLAS has joined CERES in order to leverage off the scale of CERES investor network for furthering existing and future engagements with portfolio companies located in North America.

Global Real Estate Sustainability Benchmark (GRESB)

ATLAS has been a member of GRESB since 2021.  GRESB is an industry-driven organization committed to assessing the environmental, social, and governance performance of real assets globally, including infrastructure assets, to investigate the application of its processes to the listed infrastructure sector.

Task Force on Climate-Related Financial Disclosure (TCFD)

ATLAS has utilised the TCFD recommendations in designing and developing our approach to Governance, implementation and monitoring.

Science Based Targets Initiative (SBTi)

ATLAS utilises the Science Based Targets Initiative in its establishment of portfolio emissions pathways.

Dialshifter

‘This fund is helping to ‘shift the dial from brown to green’ by…’

… embedding ESG and climate considerations throughout the investment lifecycle, across security selection, portfolio construction and ongoing monitoring, ensuring capital is allocated with a strong focus on sustainable and inclusive growth, climate action, pollution reduction and human development. Through enhanced net zero alignment assessments, fossil fuel exposure analysis, biodiversity monitoring and strengthened reporting capabilities, ATLAS continues to deepen its understanding of ESG risks and opportunities and support better long-term investment outcomes in infrastructure.

SDR Labelling:

Not eligible to use label (out of scope)