Sustainable, Responsible &/or ESG Policy:

Investment Objective

The objective of the Sub-fund is to provide capital growth, with the potential for income, over any 7-year period through investments considered by the Investment Manager to be responsible investment choices.

How will the objective be achieved?

The Sub-fund will take a responsible approach to provide at least 70% exposure to shares across any economic sector and geographic area, where it is considered to be an ethical investment choice while meeting sustainability criteria. For the purposes of this policy, assets with sustainable characteristics have features that contribute to positive environmental and/or social outcomes, alongside seeking financial returns.

Ethical investments avoid certain economic sectors that may be harmful to the environment and/or society.

At least 80% of the overall above exposures will be to assets that are considered by the Investment Manager to have sustainability characteristics. The determination of this will be made by Investment Manager through their qualitative research process. The Investment Manager will look for investments where the underlying fund has a policy to invest into such assets or where a directly held asset demonstrates sustainability characteristics verified via its qualitative research approach. This would be a holding’s investment process or business activities that promote environmental and/or social outcomes. Alternatively, the Investment Manager may select investments for which a process is in place to improve the environmental and/or social outcomes of their activities. This could be either through engagement with management of the underlying asset, a voting strategy by the Investment Manager or a documented policy from the underlying asset committing to this.

In addition to the above, the Investment Manager will apply a quantitative and qualitative assessment to filter out investments that may provide exposure to the following sectors, that are not considered to meet ethical criteria. The aim of the Investment Manager is to ensure that there is an overall limited exposure to the following sectors and no more than 10% of any single underlying investment’s exposure to:

Tobacco, Alcohol, Animal Testing (Cosmetics), Military/Armaments, Nuclear Power, Oil & Gas, Pornography, or Gambling.

To provide the above exposure, a minimum of 70% of the Sub-fund will be invested in active and/or passively managed collective investment schemes.

Research for eligible investments will focus on maximising the exposure to sustainable factors. The Investment Manager will carry out qualitative assessment both prior to asset purchases and on an ongoing basis, in order to determine the sustainability characteristics of assets.

(Source: KIID, as at December 2025)

SDR Labelling:

Unlabelled - promotes sustainable characteristics (has CFD)

SDR Literature:

• Consumer Facing Disclosure