Invesco NASDAQ-100 ESG UCITS ETF

Sustainable, Responsible &/or ESG Policy:

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 companies that meet certain ESG criteria i.e. issuers with limited/no involvement in certain business activities, with a more favourable ESG rating compared to similar issuers and with no involvement in 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 the exclusion criteria detailed in the methodology of the Reference Index 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 environmental characteristics of the Fund are achieved by tracking the Reference Index within an acceptable tracking error and in accordance with the investment policy as outlined in the Supplement.

The Reference Index is constructed by using the Index Provider’s exclusionary criteria to exclude from the Parent Index securities of issuers that:

1. are involved (as defined using data provided by Sustainalytics, an independent ESG and corporate governance research, ratings and analytics firm) in any of the following business activities: adult entertainment, alcohol, arctic oil and gas exploration, cannabis, controversial weapons, gambling, military weapons, nuclear power, oil & gaseous fuels, power generation from sources with high greenhouse gas intensity, oil sands, riot control, shale energy, small arms, thermal (including hard coal and lignite) coal and tobacco;
2. have a controversy level higher than 4 as defined by Sustainalytics;
3. do not have a Sustainalytics ESG Risk Rating Score or have a Sustainalytics ESG Risk Rating Score that is higher than or equal to 40; and
4. are deemed by the Index Provider not to comply with the principles of the United Nations Global Compact (as determined by the Index Provider using Sustainalytics data).

The exclusion criteria of the Reference Index are aligned with the exclusions for Paris-aligned Benchmarks detailed in Article 12(1)(a) – (g) of Commission Delegated Regulation (EU) 2020/1818. Involvement and revenue thresholds are defined by the Index Provider. Further information in relation to the any revenue thresholds and controversy scoring criteria, can be obtained from the Index Provider’s website.

Each of the eligible component securities is then assigned a weighting factor based on its respective Sustainalytics ESG Risk Rating Score (the lower the Sustainalytics ESG Risk Rating Score of the security, the higher the assigned weighting factor), which is applied to re-weight the eligible securities using their market value in the Parent Index to construct the weighting of the Reference Index. The reweighted eligible component securities are then additionally subject to a set of capping constraints to ensure diversification.

The Reference Index is reconstituted and rebalanced quarterly effective as of the market open on the trading day following the third Friday of March, June, September and December.

Where a previously eligible security subsequently ceases to meet the environmental or social characteristics of the Fund, or where the Fund acquires a security as a result of a corporate action and such security does not meet the environmental or social characteristics of the Fund, the Fund may continue to hold such security until such time that the security is removed as a component of the Reference Index at the next rebalance date.

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 disclosures