Invesco MSCI USA Universal Screened 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. The environmental and/or social characteristics promoted by the Fund are to increase overall exposure to companies demonstrating a robust ESG profile, as well as a positive trend in improving that profile. i.e. issuers with a more favourable or increasingly favourable ESG rating compared to similar issuers. The Fund also reduces exposure to companies involved in certain business activities and those with involvement in very severe ESG controversies. 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 10% of the Fund’s NAV will be in sustainable investments.

Process:

The ETF replicates the MSCI USA ESG Universal Select Business Screens Index that tracks the performance of large- and mid-capitalisation companies in the USA and aims to represent the performance of an investment strategy that, by adjusting the constituents’ free-float market capitalisation weights based upon certain environmental, social and governance (“ESG”) metrics, seeks to increase overall exposure to those companies demonstrating both a robust ESG profile as well as a positive trend in improving that profile. MSCI ESG metrics is a tool designed to produce a broad set of standardised ESG data and simple flagged metrics that are comparable across a broad universe of companies and used to assess the ESG profile of a company. ESG metrics cover risk exposure, controversies, performances and practices and take the following areas into account: climate change, natural capital, pollution and waste, environmental opportunities, human capital, product liability, stakeholder opposition and corporate behaviour. 

The Reference Index is further described below but only represents an extract of information available from public sources and neither the Directors, the Manager, MSCI Inc. or such other successor sponsor to the Reference Index (the "Index Provider") nor the Investment Manager take any responsibility for the accuracy or completeness of such information. 

The Reference Index is constructed from the MSCI USA Index (the "Parent Index") by using the index provider’s ESG exclusionary criteria to exclude from the Parent Index securities that:

1) have not been assessed or rated by the Index Provider on the basis of the ESG metrics;

2) have faced very severe controversies pertaining to ESG issues (including UN Global Compact violations) over the last three years; or

3) are involved (as defined by the Index Provider) in any of the following business activities: controversial weapons, conventional weapons, nuclear weapons, oil sands, thermal coal, civilian firearms, recreational cannabis and tobacco;

4) have an MSCI ESG rating of CCC; and

5) are categorised as investment trust companies. 

Each of the eligible component securities is then assigned a combined ESG score, which reflects the Index Provider’s assessment of both the security’s current ESG rating, as well as the trend in that rating, defined as the change in the security’s ESG rating over time (the “Combined ESG Score”).This Combined ESG Score is then applied to re-weight the eligible securities from their free-float market cap weights in the Parent Index to construct the weighting of the Reference Index.  

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)