Sustainable, Responsible &/or ESG Policy:

Objective:

The investment objective of the Fund is to generate a combination of capital growth (the increase in value of investments) and income (money paid out by an investment, such as a dividend from a share or from a fund) over an investment term of 5 year rolling periods. Capital growth will be prioritised over income generation.

Policy:

The Fund uses a global multi sector approach to achieve its objective. The Fund will invest, in UK listed companies (directly and indirectly) and global listed companies (indirectly). Indirect exposure will be achieved by investing between 60-90% of the Fund in thematic funds (such as specific sector themes for example, clean energy, nutrition, insurance or other general themes which are aligned with at least one of the UNSDG (UN Sustainable Development Goals) goals) and global equity funds (where the manager can demonstrate alignment of holdings to UN SDGs). Fund investments will be made in a range of vehicles including, in each case, open-ended funds, exchange-traded funds and closed ended investment companies. The Fund will invest between 10-40% directly in UK listed companies and can hold up to 20% in cash.

The Fund will not invest more than 25% in any single collective investment scheme.

The Fund can invest in other funds managed by the ACD or its associates.

The Investment Manager seeks to ensure that both direct and indirect investments (investments within collective investment schemes) address at least one of the UN Sustainable Development Goals (“UN SDGs”). The extent to which each holding addresses a UN SDG will be determined based upon qualitative and quantitative analysis. Qualitative analysis can be gained through company meetings and research, whilst quantitative from company reports and third parties.

Material improvement by companies towards UN SDGs is an important component of this analysis. Therefore, whilst the Fund will invest in companies that already operate in a responsible manner according to one or more of the UN SDGs, the Fund will also invest in companies which may not currently do so, but which (according to the Investment Manager’s documented analysis) are making material improvements in their business practices towards meeting at least one of the UN SDGs.

The Investment Manager will regularly monitor the companies in which the Fund invests against the above criteria and if the company no longer meets the UN SDGs or is no longer making improvements towards the UN SDGs, the Investment Manager will withdraw its investment in that company.

Assessment of the credentials of underlying fund managers, from the perspective of ‘responsibly’, is conducted through two main approaches. The first is through the Investment Manager’s proprietary ‘ESGi Framework’, a rating system developed by the Investment Manager that is based on meetings and a questionnaire sent to asset managers. This enables the Investment Manager to better understand the extent to which ESG risks are considered within underlying funds. The Investment Manager believes that the MW Proprietary system is better than relying on an external ratings system as opinion can differ widely between different providers on companies or funds. The second is through seeking to identify the manager’s understanding of and alignment with the UN SDGs. The managers also seek to identify managers that can demonstrate an alignment to the UN SDGs through their holdings.

Whilst the Investment Manager does not formally operate negative screening criteria, it is unlikely that companies will be held in certain sectors such as tobacco, gambling, coal or oil and gas unless either their interest were under 10% of revenue, or no new capital was being allocated to these areas as the company transforms itself away from these activities.

The Fund is actively managed.

(Source: KIID, as at Janaury 2025)