Invesco Global Clean Energy UCITS ETF

Sustainable, Responsible &/or ESG Policy:

In order to achieve the investment objective, the Fund employs a replication method that looks to invest as far as possible and practicable in the constituents of the Reference Index. As such, the fund replicates the Sustainable, Responsible &/or ESG Policy embedded in its Reference Index.

This Fund promotes environmental and/or social characteristics but does not have as its objective sustainable investment, however the Fund intends to make sustainable investments. The environmental and/or social characteristics promoted by the Fund are to gain exposure to global companies whose innovative technologies contribute to the generation and utilisation of cleaner energy, conservation, efficiency and the advancement of renewable energy. The Fund achieves this by tracking the Reference Index, which has a methodology that is consistent with attaining the environmental and social characteristics promoted by the Fund.

Through a combination of the exclusion criteria detailed in the methodology of the Reference Index and the qualitative assessment and/or engagement of Invesco’s ESG team, it is ensured that investee companies follow good governance practices. The Fund takes into account the PAI indicators defined in Table 1 of Annex I of the RTS and ensures alignment with the OECD guidelines and UNGP, thereby ensuring that the sustainable investments do not cause any significant harm to environmental and/or social objectives.

A minimum of 90% of the Fund’s NAV will be selected according to the binding elements of the investment strategy. Up to 10% of the Fund’s NAV may not be aligned with the environmental and/or social characteristics of the Fund, this portion of the Fund may be invested in financial derivative instruments for hedging and/or efficient portfolio management purposes and cash for ancillary liquidity purposes. A minimum of 90% of the Fund’s NAV will be in sustainable investments.

Process:

The ETF tracks the WilderHill New Energy Global Innovation Index, which is designed to reflect the performance of global companies whose innovative technologies focus on the generation and use of cleaner energy, conservation, efficiency and the advancement of renewable energy. It is mainly composed of companies focused in wind, solar, biofuels, hydro, wave, tidal, geothermal and other relevant renewable energy businesses, as well as energy conversion, storage, conservation, efficiency, materials relating to those activities, carbon and greenhouse gas reduction, pollution control, emerging hydrogen and fuel cells. 

The Reference Index is further described below but only represents an extract of information available from public sources and none of the Directors, the Manager, Solactive AG ("Solactive"), WilderHill New Energy Finance, LLC ("Wilderhill") or such other successor sponsor to the Reference Index nor the Investment Manager take any responsibility for the accuracy or completeness of such information.

Solactive is responsible for decisions regarding the composition of the Reference Index and Solactive defines the universe of the Reference Index. The universe of the Reference Index is currently comprised of 15  companies incorporated in, or whose shares are listed in any of the following 27 countries: Australia, Austria. Belgium, China, Canada, Denmark, Finland, France, Germany, Hong Kong, Ireland, Israel, Italy, Japan, Netherlands, New Zealand, Norway, Poland, Portugal, Singapore, South Korea, Spain, Sweden, Switzerland, Taiwan, United Kingdom and United States. The universe of the Reference Index may change to include/exclude countries at the discretion of Solactive.

To be eligible for inclusion in the Reference Index, companies shall be assessed to determine whether it is involved in activities which have adverse impacts on societies and ecosystems from an environmental, social and governance standpoint. To that end, and using data provided by Sustainalytics, Solactive will, in accordance with the methodology for the Reference Index, exclude companies that are:

• not compliant and in violation of international norms and standards, such as the UN Global Compact Principles, the International Labour Organization’s (ILO) Conventions, OECD Guidelines for Multinational Enterprises and the UN Guiding Principles on Business and Human Rights (UNGPs);
• identified to have a severe controversy rating (as set out in the methodology for the Reference Index), with controversy defined as an event or series of events with negative environmental, social and/or governance implications;
• engaged, from a business involvement perspective, in a number of harmful activities and products such as controversial and conventional weapons, thermal coal, tobacco, cannabis for recreational purposes and unconventional oil & gas (arctic oil, oil sands and shale energy). Such exclusions may vary depending on the activity, from zero tolerance to exclusions based on percentage of revenue or other measures as more fully set out in the methodology for the Reference Index;
• identified to have a severe ESG risk rating (as set out in the methodology for the Reference Index). The ESG risk rating evaluates the degree of a company’s unmanaged material ESG risk by assessing a company’s exposure to, and management of, the ESG issues that are considered most material for that company from a financial perspective.

Where Sustainalytics data for a company is not available to complete an assessment for involvement in the above-mentioned activities, the company will not be eligible for inclusion in the Reference Index.

Based on the universe of the Reference Index, Wilderhill is responsible for determining if a company falls into one of the below sectors. Affiliation of a company to a Sector is estimated by Wilderhill with respect to the below Sector definitions and companies assigned to one of the below sectors are selected as components of the Reference Index. The inclusion of a company to a Sector is based on meaningful exposure to clean energy with a company being required to have the primary part of its business activities with a focus on new energy innovation as described in the Sector definitions (generally, primary business activity is taken to mean that a company derives at least 10% of its market value from activities in clean energy, as determined by Wilderhill)– and without fossil fuel exposure other than described in the Sector definitions. If companies are active in multiple Sectors, the Sector assignment is always based on the primary activity of company. This process to determine affiliation of a company to a Sector is based on, inter alia, screening company descriptions based on bona-fide sources (as determined by Wilderhill, including official corporate disclosures, recognised industry publications and corporate presentations), company annual filings and websites.

Sectors

• Renewable – Wind: Eligible companies for the wind sector are involved in manufacturing of components, parts and subassemblies for wind turbines, or are manufacturers of turbines themselves. Additionally, developers, generators, utilities and engineering firms that are engaged in building wind farms around the world are eligible.
• Renewable – Solar: Eligible companies are engaged in technologies that capture energy from the sun, using photovoltaic (PV) material, or via solar thermal technologies such as concentrators.
• Renewable – Biofuels & Biomass: Eligible companies are suppliers of biofuels, suppliers of the processing technologies and equipment, logistics and distribution players, manufacturers of energy systems specially adapted for the use of biofuels and products, as well as companies involved in production and consumption of solid or gaseous fuels derived from biomass. Solid biomass can also consist of crop residues such as straw. Other waste matter for energy generation will only be 16 included if the energy generation is low carbon. Liquid transportation fuels including biodiesel and bioethanol can be derived from a range of biomass sources, including sugar cane, rapeseed/canola, soybeans, and cellulosic biomass.
• Renewables – Other: One of the characteristics of the clean energy industry is it is based on making sustainable use of a diverse range of renewable energy sources. Eligible companies under this sector include companies active in renewable categories other than solar and wind. For example, geothermal power has long played a part in the energy mix of countries with natural geothermal resources, such as Japan. Companies involved in Hydroelectric can be eligible too as the world shifts to new energy solutions with interesting advances in smaller-scale, low-head hydro and even micro-scale.
• Energy Efficiency: Companies eligible for inclusion in this sector are working to deliver improvements in efficiency of existing generation and distribution systems. Important technologies include software to improve electricity demand management or reduce grid losses, breakthroughs in motor or generator design or technologies for combined heat and power (i.e. those which enable the capture and use of waste heat from power generation). Furthermore, companies engaged in technologies that reduce use of energy in homes, retail and commercial buildings can be eligible. These activities include building components that reduce energy use, intelligent systems for managing power consumption and technologies that more efficiently use power.
• Energy Conversion: Eligible companies are active in conversion technologies and fuels. Hydrogen & fuel cell technology is included, from production and storage of hydrogen, to distribution as well as related technologies. Advanced turbines, and lower-carbon fuel systems may also be covered in this sector, as well as potentially whole systems such as alternative fuel vehicles allowing renewables to power new greener transportation.
• Energy Storage: Renewable solar, wind, and other green technologies typically harness natural resources that are either intermittent or have response curves that are unable to follow the dynamic demands that are put on them when deployed. Batteries and other energy storage technologies may become key enablers for large-scale shift to these greener technologies. Eligible companies for the energy storage sector are engaged in newly emerging storage technologies, and extant mechanical technologies like flywheels, and components like ultra-capacitors which are potentially complimentary with batteries. Systems built around large-scale storage such as electric vehicles, electric cars, electric buses, electric ships, trains and planes etc. are eligible as well.

Companies considered for inclusion in the Reference Index are also assessed based on whether they are deemed to contribute to decarbonisation and to reduce climate risk generally. To ensure that all components of the Reference Index are considered to be sustainable, in addition to determining the affiliation of a company to a Sector, Wilderhill also assesses each company against sustainability criteria including: low Greenhouse Gas (GHG) emissions, low or no exposure to the fossil fuel sector, small or no exposure to non-renewable/or nuclear energy production and consumption, low association to activities that negatively affect biodiversity-sensitive areas, low or no pollution, and low or no emissions into water/seas, and a low hazardous waste ratio. 

In order to be eligible for inclusion in the Reference Index, securities must also meet the following criteria as defined by Solactive from a liquidity and tradability perspective: 

• Have a listing on a major international or national exchange; and
• Have a three-month average market capitalization of at least USD$100 million measured over the preceding three-month period; and
• Have an average daily trading volume over the preceding 3 months larger than USD$1 million for new components to be added and USD$750,000 for current components to remain. Securities that have recently been through an initial public offering (IPO) may be included where there is sufficient volume, as determined by Wilderhill.

Stock selection for the Reference Index is biased in favour of “purer play” companies in renewable energy and those in cleaner energy generally. “Purer play” means those companies that derive more than 50% of their market value from their clean energy activities. Up to 80% of the constituents of the Reference Index are expected to comprise “purer play” companies.  The Reference Index is calculated by equally weighting each security as determined on the Selection Date, to be implemented on the Rebalance Date.

These Wilderhill criteria to determine whether a security can be included in the Reference Index include but are not limited to:

(a) size of the IPO (i.e. market capitalisation of the new company);

(b) degree of broad investor interest and activity (e.g. demand for the IPO, as indicated by the pricing stock relative to indicated ranges and trading volumes and price action on the initial days of trading);

(c) realised trading volumes over whatever time period data is available since IPO;

(d) degree to which the company represents a significant component of the global clean energy ecosystem (with more central / significant companies receiving a greater degree of interest and investment from the broad market); and

(e) likelihood of the security being included into other benchmark indices and therefore attracting other passive flows.

Resources, Affiliations & Corporate Strategies:

Investment Stewardship at Invesco

Invesco’s dedicated Investment Stewardship team comprises over 40[1] stewardship specialists who provide expertise and support to investment teams who manage products in line with client objectives, stated investment strategies and applicable regulatory requirements. The team serves as a strategic resource to support, inform and guide Invesco’s investment teams globally on stewardship activities, including corporate governance, proxy voting and engagement, sustainable investing, and thematic investment research. Our client-centric approach is rooted in our commitment to long-term value creation for clients.

We view stewardship as a core responsibility of asset management. It encompasses our duty to act in the best interests of our clients, using our investment expertise and resources to support outcomes aligned with our clients’ objectives. This includes engaging with companies, voting proxies on behalf of clients, contributing to industry dialogue, and transparently reporting on our stewardship activities, all of which is conducted in accordance with applicable regulatory requirements and client commitments. For relevant strategies and clients, it also includes our sustainable investing capabilities.

Our Organizational Structure

The Investment Stewardship team is organized across four pillars to support investment teams across asset classes and geographies:

 Corporate Governance & Advisory

This team provides governance expertise and supports stewardship across global investment teams. The core responsibility of this team is to support investment teams in considering corporate governance factors within their investment process and to contribute to proxy voting decisions in alignment with Invesco’s stewardship principles. The team collaborates with investment teams in conducting corporate governance engagements and actively participates in industry-wide initiatives and regulatory consultations. It includes our proxy operations and voting capabilities, which execute proxy voting across thousands of shareholder meetings annually.

Stewardship Strategy, Operations & Reporting

This team ensures investment stewardship business planning aligns with Invesco’s firm-wide strategy, incorporating the firm’s priorities into our roadmap and project prioritization. It is responsible for strategy execution, operational alignment, and organizational efficiency across the Investment Stewardship department. The team manages global stewardship workflows, policy implementation, external reporting, and communications, while maintaining operational integrity and regulatory compliance.

Investment Stewardship Analytics

This team supports global stewardship through analytics, portfolio screening, and data vendor management. This team ensures investment teams have access to high-quality, decision-useful information. It also maintains data systems to streamline proxy voting and engagement workflows.

Sustainable Investing Services (SIS)

This team provides expertise and insights on environmental and social topics to support investment decision-making by conducting proprietary research and contributing to meeting client objectives for relevant products and strategies. It partners with investment teams, distribution, and clients to support engagement on sustainability topics and to meet strategy and client-specific commitments.

Global Collaboration and Governance

The Investment Stewardship team includes professionals located in North America, Asia Pacific, and EMEA, providing localized support and analysis to our investment teams across the globe. Our stewardship professionals collaborate closely with investment teams, providing support, insights, and analysis while investment teams maintain discretion on portfolio decisions. In addition, Invesco has dedicated specialists within individual investment teams across the globe who are closely connected with the Investment Stewardship team.

Our governance structure enables oversight and accountability through the Investment Stewardship Leadership Committee, comprised of senior members of the firm from various functions. This ensures that our investment teams receive appropriate guidance on stewardship considerations that are relevant to their investment strategies and processes. We also monitor external service and data providers through regular reviews and audits, meet routinely with major vendors to align methodologies and resolve issues, and increasingly automate data controls (timeliness, conformity, completeness and accuracy) for sources used in portfolio monitoring and compliance. Where gaps arise, we work to resolve them and continue to evaluate new data sets and approaches as sustainability‑related data evolves.

[1] Figure as of 31 March 2026. 

SDR Labelling:

Not eligible to use label (out of scope)

SDR Literature:

• Sustainability related disclosure
• Sustainability full disclosure