Sustainable, Responsible &/or ESG Policy:

The Fund is built upon the foundations of the Janus Henderson Global Technology Leaders Strategy, founded in 1983, one of the largest and longest running technology strategies in Europe. The Global Technology Leaders Team has been investing through a lens of innovation, disruption, navigating the technology hype cycle and integrating ESG factors for more than 20 years. The Sustainable Future Technologies Strategy has been born out of our experience, our research into sustainable technology investing as well as taking inspiration from the Janus Henderson Global Sustainable Equity Strategy, that was founded in 1991. Our focus on technology companies means the strategy naturally avoids the most carbon intensive sectors of the economy and others that have negative externalities, such as environmental pollution, violence and armed conflict, and smoking.

As part of our investment process the Fund employs both positive and negative screening according to a range of themes and sectors. We see significant overlap within our investment themes and the 10 impact investing themes from the UN PRI’s Impact Investing Market Map. We believe that the Fund links directly to 8 of the 10 themes as follows:

• Energy efficiency aligns with our Clean Energy Tech themes
• Green buildings is fully aligned with our Low Carbon Infratructure and Smart Cities themes
• Renewable energy aligns directly to our Clean Energy Technology theme
• Sustainable agriculture aligns to our Resource and Productivity Optimisation theme
• Water aligns to our Resource and Productivity Optimisation
• Education – aligns to our Digital Democratisation theme
• Health – Aligns directly with our Tech Health theme
• Inclusive finance – Aligns directly to our Digital Democratisation theme
• Sustainable forestry – no current direct alignment with our technology themes
• Affordable housing – no current direct alignment with our technology themes

Thematic framework

The positive selection criteria leads the team to invest in businesses that have a positive impact on society and the environment by virtue of the technology products or services they offer, and by the way in which they manage their operations, thereby supporting the UN SDGs.

Positive screening – identifying companies on the right side of environmental and social trends

The sustainable thematic screen guides our idea generation and identification of long term-opportunities created by major sustainable technological shifts. Investments in the portfolio must derive at least 50% of current or future revenues up to a maximum of five years from the investment team’s sustainable technology themes. The revenue mapping is carried out by the investment analysts, utilising their deep tech sector expertise. For thematic integrity, the team’s dedicated sustainability analyst provides support and oversight, assisted by the ESG Corporate Research Team. The strategy’s thematic allocation is dynamic and there is no forced distribution among themes.

Environmental themes

Clean Energy Tech
Innovative technological solutions designed to reimagine the most carbon intensive areas of the economy meeting the challenge of resources constraints, population growth and climate change.
Investment areas include: renewable energy technology, battery technology, smart grids, smart power.

Sustainable transport
Technology to enable the transition to zero emission vehicles, ride hailing, autonomous driving and automated logistics with the goal of climate change adaptation and mitigation.
Investment areas include: electric vehicles, computer vision, sensors, battery management, navigation, platforms.

Low carbon infrastructure
Compute proliferation drives an exponential leap in power consumption, a climate change and resource constraint challenge that requires the transition to low carbon cloud and 5G architecture.
Investment areas include: data centres, Moore’s Law, 5G infrastructure, platforms, software.

Smart cities
Sustainable cities need to be smarter to meet the challenges of a growing and ageing population, resource constraints and climate change necessitating digital transformation and greater connectivity.
Investment areas include: 5G mobility, Internet of Things (IoT), edge compute, smart communications.

Social themes
Resource & productivity optimisation
A growing and ageing population, resource constraints and climate change require technological innovation to boost productivity and to optimise the efficient use of scarce resources.
Investment areas include: digital design, collaboration tools, artificial intelligence, digital productivity, asset tracking.

Digital democratisation
A growing and ageing population beset by rising poverty and inequality requires technological innovation to enable access to quality education and promote financial inclusion.
Investment areas include: AI, data analytics, fintech, edtech, platforms, data access.

Tech health
A growing and ageing population beset by rising poverty and inequality requires technological innovation to enable access to quality healthcare and improved outcomes.
Investment areas include: Medtech, AI, data analytics, platforms.

Data security
A digital and AI world built on big data and analytics in the cloud requires secure and fair data usage to protect our fundamental human right to privacy and our digital identities.
Investment areas include: network security, secure cloud, identity protection, data privacy.

Process:

To deliver our dual mandate, there are six stages to our sustainable investment process incorporating both positive and negative selection criteria, including product and operational impact analysis. Navigating the hype cycle of sustainable future technologies is supported by the five interlinking pillars of our rigorous investment framework integrating sustainability at every level:

1. Positive screening: applied via a positive thematic overlay of eight long term sustainable technology themes with alignment to the UN SDGs
2. Negative screening: strict avoidance criteria are adopted. We will not invest in activities that contribute to environmental and social harm (subject to a de minimis rule). This also helps us avoid investing in industries most likely to be disrupted.
3. Bottom-up fundamental research: incorporating triple-bottom line analysis, integrating ESG and financial analysis and evaluating how companies focus on profits, people and the planet in equal measure.
4. Valuation discipline: seeking underappreciated earnings growth potential and rational growth at a reasonable price and incorporating ESG insights
5. ESG insights and proactive engagement: evaluation of potential ESG issues and development of engagement plans with a focus on continuous, direct, pro-active engagement which is a key aspect of our process.

Thematic framework
The positive selection criteria lead the team to invest in businesses that have a positive impact on society and the environment by virtue of the products or services they sell, and by the way in which they manage their operations, thereby supporting the United Nations Sustainable Development Goals (SDGs) adopted in 2015.

1. Positive screening – identifying companies on the right side of environmental and social trends

The positive impact thematic overlay and positive screening guides our ideas generation and identification of long term-opportunities created by major technological shifts. Investments in the portfolio must derive at least 50% of current or future revenues from these sustainable technology themes. For thematic integrity the independent ESG Investment Team provides portfolio oversight ensuring true alignment with themes.

Environmental themes

Clean Energy Tech
Innovative technological solutions designed to reimagine the most carbon intensive areas of the economy meeting the challenge of resources constraints, population growth and climate change.
Investment areas include: renewable energy technology, battery technology, smart grids, smart power.

Sustainable transport
Technology to enable the transition to zero emission vehicles, ride hailing, autonomous driving and automated logistics with the goal of climate change adaptation and mitigation.
Investment areas include: electric vehicles, computer vision, sensors, battery management, navigation, platforms.

Low carbon infrastructure
Compute proliferation drives an exponential leap in power consumption, a climate change and resource constraint challenge that requires the transition to low carbon cloud and 5G architecture.
Investment areas include: data centres, Moore’s Law, 5G infrastructure, platforms, software.

Smart cities
Sustainable cities need to be smarter to meet the challenges of a growing and ageing population, resource constraints and climate change necessitating digital transformation and greater connectivity.
Investment areas include: 5G mobility, Internet of Things (IoT), edge compute, smart communications.

Social themes

Resource & productivity optimisation
A growing and ageing population, resource constraints and climate change require technological innovation to boost productivity and to optimise the efficient use of scarce resources.
Investment areas include: digital design, collaboration tools, artificial intelligence, digital productivity, asset tracking.

Digital democratisation
A growing and ageing population beset by rising poverty and inequality requires technological innovation to enable access to quality education and promote financial inclusion.
Investment areas include: AI, data analytics, fintech, edtech, platforms, data access.

Tech health
A growing and ageing population beset by rising poverty and inequality requires technological innovation to enable access to quality healthcare and improved outcomes.
Investment areas include: Medtech, AI, data analytics, platforms.

Data security
A digital and AI world built on big data and analytics in the cloud requires secure and fair data usage to protect our fundamental human right to privacy and our digital identities.
Investment areas include: network security, secure cloud, identity protection, data privacy.

2. Negative screening – companies on the wrong side of these trends are subject to disruption

The negative global impact from the cost of economic externalities such as environmental pollution, violence and armed conflict, and smoking is becoming increasingly recognised. We seek to avoid those businesses involved in activities that are harmful to society or the environment via clearly defined standards that govern the companies we exclude from our investment universe. Our exclusions provide ethical, social, environmental, and financial benefits.

UN Global Compact (norms-based screening)
All holdings are compliant with the UN Global Compact, whose 10 principles cover human rights, the International Labour Organisation’s Declaration on workers’ rights, corruption, and environmental pollution. This provides minimum safeguards for the investments in the strategy.

UN Global Compact (norms-based screening)
All holdings are compliant with the UN Global Compact, whose 10 principles cover human rights, the International Labour Organisation’s Declaration on workers’ rights, corruption, and environmental pollution. This provides minimum safeguards for the investments in the strategy.

Exclusion criteria
At a corporate level, we utilise a third-party vendor to compare all companies, including their beneficial owners, and as appropriate, directors, against sanctions lists maintained by the Office of Foreign Assets Control (OFAC, US), the European Union, the United Nations and multiple countries including Canada, Australia, Switzerland, and the UK.

The strategy naturally and explicitly excludes investment in multiple sectors which have many negative externalities, such as environmental pollution, violence and armed conflict, and smoking, and have a detrimental effect on the global economy subject to a de minimis rule (for further details on this, please refer to our Investment Principles document).

3. Bottom-up fundamental research – triple bottom-line approach

We assess the positive impact, organic growth potential, the size of the addressable opportunity, barriers to entry, ESG operational risks and management quality. The nature of the competitive advantage of the moat and whether that is increasing or decreasing has implications for margins. We look for companies where we believe the management quality, growth rate or the sustainability of that growth rate is underappreciated. Via bottom-up fundamental research and proprietary forecasting we seek to identify unexpected earnings or cashflow growth as a core tenet of every investment case. Positive impact and ESG leadership are integrated into a proprietary sustainability rating and into our valuation framework.

The team is ultimately analysing every company on the basis of the ‘3 Ps’ of their triple bottom line: how they generate profits, how they impact people; and how they impact the planet. Gaining a deep understanding of all of these elements of a company’s fundamentals is a critical aspect of the ‘five stages’ of the team’s investment process, and each company is assessed on this basis.

4. Valuation discipline – a belief in valuation discipline as a guide to unappreciated earnings growth

Valuation discipline is a key defining part of our bottom-up research. The focus is on rational growth at a reasonable price (GARP). We do not believe that pure ‘value’ investing is appropriate in a dynamic sector like technology and seek to avoid companies that are in secular decline. We are disciplined in our approach utilising a variety of valuation approaches used by sector specialists, which are all focused on future earnings and cashflow. We also integrate sustainability and ESG criteria into our valuation assessment to help assess the appropriate premium/discount to the market. Our proprietary master valuation spreadsheet monitors all our target prices, earnings momentum and share price performance, while our ESG process monitor control allows us to identify ESG indicators relevant to the valuation framework.

5. ESG insights and pro-active engagement

We believe that financial indicators have strong non-financial roots. As active managers with superb access to senior management, we take a pro-active approach to communicating views to companies and seeking improvements in performance and standards of corporate responsibility and core principles such as disclosure, transparency, and consistency. Each company held in the portfolio is reviewed in relation to its environmental social and governance risks as outlined in the following engagement framework.

The strategy has a dual mandate with a sustainable objective and promotes environmental and social characteristics via its portfolio commitments, for example on decarbonisation and board gender diversity.

We consider our approach to voting and engagement as ‘evidence-based’, systematic and pragmatic. These are reviewed using a variety of information and data taken either directly from the security issuer or from third parties (research providers, index providers, consultants). The following ESG data providers are used to inform our ESG analysis. We use a variety of information sources including security issuers and third-party research providers and consultants to rank and assess our investee companies. The sources include, for example:

• MSCI, main firmwide strategic provider
• Sustainalytics
• Bloomberg
• Vigeo EIRIS
• Institutional Shareholder Services (ISS)
• RepRisk

We monitor each company’s performance and ESG disclosure against key metrics. Using our proprietary ranking screen, we rank our investment universe of over 700 companies on a broad range of internal and external ESG data points and principles to identify leaders, those which are transitioning and companies who are lagging, which feeds into both our valuation framework and our engagement. Materiality is assessed based on SASB Standards, Global Reporting Initiative (GRI), EU Principal Adverse Impacts (PAI), Task Force on Climate-Related Financial Disclosures (TCFD), Taxonomy, our dedicated sustainability analyst and teams understanding of ESG and technology. The process control monitor is a dashboard of key ESG indicators and our revenue mapping. Using these tools and through our engagement we implement the do no significant harm criteria and minimum social safeguards (for example via UNGC and OECD MNE Principles), while promoting environmental and social characteristics. Our dedicated sustainability analyst ensures implementation of ESG principles.

We recognise that such information or data may be incomplete, inaccurate, or inconsistent given the limitations of static scoring of complex issues with imperfect data. In such situations, the investment team’s extensive experience, deep sector expertise, industry contacts and support from the ESG Corporate Research Team may prove beneficial.

We engage directly with companies via formal and informal meetings, calls and in writing, providing thought leadership in engagement on complex social and environmental issues.

We actively manage our positions for controversies and risk incidents, which also shapes our engagements. Engagement work can be company specific or thematic-led and represents a mixture of proactive and reactive engagement.

Engagement topics include for example: performance and policy standards on deforestation, biodiversity, diversity, equity and inclusion (DE&I), education, research and development (R&D), renumeration, data privacy and security, and tax. As technology specialists we believe we are well positioned to understand the disruptive aspects of technology and potential future ESG issues that may arise. In the past this has been reflected in our engagement on topics ranging from mental health impacts of social media, taxation policy of mega-cap companies, whistle-blower policy standards, the balance of data security and privacy and the effects and controls on casual gaming.

We are action-orientated and address areas for improvement through formalised action plans with clear objectives and timeframes. A lack of progress or negative ESG momentum may prompt a revisit of the investment case and lead to an exit from the stock.

The strategy avoids ESG laggards, companies with high controversies, and negative ESG momentum as defined by third party data, our ESG principles, proprietary ESG ranking screen and process control monitor, as well as our action plans and engagement. We will use engagement to promote best-in-class practices, for example on decarbonisation targets and data privacy & security. We may hold companies that score poorly due to a lack of disclosure, notably smaller companies, or due to minor ESG issues if we have a positive outlook on near-term improvements via engagement, which may be formalised within an action plan including clear objectives and timelines. In addition to the investment team’s focus, which includes input from our dedicated sustainability analyst, the Governance & Stewardship Team also identifies further issues and facilitates collaboration with other investors to enhance engagement influence.

The SFT strategy adopts a low-carbon approach, based on exclusionary criteria, ESG commitments and engagement.

Stock selection

Our universe is shaped by our negative screening exclusion criteria and by our positive screening and thematic requirements.

Any investee company must derive at least 50% of their future expected revenues from the sustainable technology themes the investment manager has identified, thereby having a clear positive environmental or social impact. As well as the products and services generating revenues, the operations of the business will also be assessed for alignment with the UN’s sustainable development goals as indicated by the UNPRI guidelines.

The team operates as sub-sector analysts to foster deep understanding and expertise of industry verticals, management teams and competitive dynamics. This depth of knowledge and focus facilitates a more holistic view of how product and services fit within the sustainable technology themes outlined above, of management quality as well as their earnings trajectory relative to consensus estimates. This is overlaid with a rigorous valuation discipline that defines the investment process and is tailored to specific sub-sectors rather than using a one size fits all approach. Based on this stock selection process, the team assigns a stock rating from one (highest upside/highest conviction) to five (low/no conviction upside).

The investment team has a long track record of technology investing, ESG factor assessment, and pro-active engagement focused on sustainable growth. This experience is supplemented by a dedicated team sustainability analyst who in conjunction with the fundamental research analyst, provides a systematic assessment of the positive impact of our holdings (social and environmental) as well as assessing several key indicators of a company’s evolution with regards to its disclosure, management, governance, progress, and risk. Factors for monitoring and analysis are aligned with the UN Global Compact Principles as well as the required technical standards of global sustainable finance regulation. The team have developed a process control monitor (PCM) and proprietary ESG ranking screen to reflect these considerations, which are then reflected in the stock rating.
This combination of qualitative and quantitative review results in a sustainability rating for each holding with one (highest alignment in revenues and operations) to three (more limited disclosure, engagement required). Negative screening criteria ensure no stocks rated four or five would be held in the portfolio.

The combination of analyst rating and sustainability rating are key inputs in portfolio construction.

Resources, Affiliations & Corporate Strategies:

As at 31 March 2025, Janus Henderson has 32 Responsibility Team resources. This centralised team are our ESG subject-matter experts who partner with our investment teams on ESG. On our investment teams, we have 12 dedicated ESG experts embedded within numerous investment teams. Additionally, we have 18 portfolio managers* on Janus Henderson’s Brighter Future (ESG-focused) Funds. Our portfolio managers are further supported by our central research functions and/or investment team analysts.

Source: Janus Henderson Investors, as at 31 March 2025.

*Portfolio managers manage multiple strategies, so may not be fully dedicated to ESG-focused products. Note: the methodology to calculate this data has changed and previously included portfolio managers who manage ESG-integrated funds rather than ESG-labelled products.

Our approach to Responsibility

Janus Henderson has a three-pronged approach to Responsibility.

• The first is our own corporate responsibility. Our commitment to responsibility extends to our corporate practices, embodying the principle that ‘Responsibility starts at home.’ We need to ensure our own policies and practices reflect what our stakeholders demand. At a corporate level, behaving responsibly impacts our people, our culture, and our choices with the ultimate aim of investing in a brighter future for our clients. We leverage our influence to responsibly deliver value to our clients, employees, shareholders, and the wider community.

• The second is ESG integration. At an investment level, we integrate financially material ESG factors into our analysis and processes for most of our actively managed strategies, as appropriate, to help us identify opportunities and risks and to drive the long-term value of the companies in which we invest.

• The third is our JHI Brighter Future Funds. For those clients who want to invest for a purpose beyond risk and return, we have and continue to build our suite of ESG-focused strategies that go above and beyond integration to have ESG considerations at their core alongside the primary financial objective.

Responsible Investment Policy overview and Integration

Janus Henderson’s has had a Responsible Investment Policy since approximately 2001, referring to the legal Henderson policy established at this time. In 2023, we implemented our revised Responsible Investment Policy, which sets out our approach to Responsible Investing and ESG Governance and Oversight.

As an active manager, integrating financially material ESG factors into our investment decision-making and ownership practices is fundamental to delivering the results our clients seek from us. Financially material ESG considerations are a key component of the investment processes employed by our investment teams for most of our actively managed strategies. Our investment teams operate and are structured in ways most suited to their respective asset classes. Aside from expectations outlined within our Responsible Investment Policy, the precise approach to and depth of ESG integration is down to the discretion and judgement of our investment teams, who apply their differentiated perspectives, insight and experience to identify sustainable business practices that can generate long-term value for investors. While the evaluation of our implementation of ESG criteria is carried out at the strategy level, our central Responsibility Team supports each team in their ESG integration with data, tools, stewardship, and ESG research.

Engagement and stewardship approach

Engagement and stewardship are integral and natural parts of our long-term, active approach to investment management. We believe engagement is vital to understanding and promoting practices that position the companies and issuers we invest in for future financial success.

Our investment teams often partner with our central Responsibility Team on engagements with company management teams. We prefer an engagement-focused approach to a firm-level exclusion or divestment policy for companies and issuers where we have identified financially material ESG risks. We believe this approach is best for maximising risk-adjusted returns for our clients.

We have a wide range of engagement themes and topics chosen by individual investment teams or the Responsible Investment and Governance Team, which is part of the broader Responsibility Team. These range from longstanding engagement themes such as climate change and diversity, equity & inclusion, to biodiversity, human capital and culture, health and wellbeing, and sustainable corporate governance.

Most products and services offered by a company or issuer play necessary roles for the global economy – including sectors with higher carbon emissions such as energy, industrials, materials, and utilities. Rather than ignoring companies or issuers in these sectors through automatic exclusion or divestment, engagement leads to two benefits:

• Insight: Knowledge gained through engagements with companies or issuers can be leveraged in the investment process to better inform our research, financial modeling, and investment decisions. Engaging for insight helps us assess the magnitude of any potential risk, how well a company or issuer is managing that risk, and the potential impact on that company or issuer’s financial outcomes.
• Outcomes: Where a company or issuer may be ignoring or not managing a financially material ESG risk, engaging for outcomes can encourage that company or issuer to adopt policies or practices that will address that risk and better position it for the future.

Engagement with the company or issuer’s management or board of directors directly link the ESG consideration to why we believe addressing it makes them a better company, leading to improved cash flows, valuations, cost of capital, or credit ratings. In 2024, we conducted a total of 716 engagement discussions – 666 for insight and 50 for outcomes.

Stewardship is an integral and natural part of Janus Henderson’s long-term, active approach to investment management. We believe that strong ownership practices such as management engagement can help protect and enhance long-term shareholder value.

We support a number of stewardship codes, such as the UK Stewardship Code, and broader initiatives around the world including the UN-supported Principles for Responsible Investment (PRI). We are pleased that the PRI has recognised the significant progress we’ve made in advancing our responsible investment capabilities over the last three years and maintained our high scores in our latest assessment through June 2024. We also continue to remain a signatory to the Financial Reporting Council’s UK Stewardship Code, regarded as a benchmark in investment stewardship.

Our commitment to clients

Janus Henderson understands responsible investing continues to evolve and mature. We are committed to maintaining an open dialogue with our clients, shareholders, employees, industry groups, and regional regulators to ensure we continue to meet their expectations and hold true to our values as a steward of our clients’ capital. This includes listening to client needs and developing new products to meet changing requirements. It also means actively sharing the views of our managers on how they see financially material ESG issues reshaping the investment landscape and where the risks and opportunities lie. The Janus Henderson website provides access to manager insights as well as our Responsibility policies, voting records and annual reports.

Janus Henderson Investors Brighter Future Funds

Many of Janus Henderson’s clients want to invest for a purpose beyond risk and return and, to meet the needs of these clients, we’ve developed our JHI Brighter Future Funds, a suite of ESG-focused portfolios that go above and beyond integration to have ESG at their core alongside the primary financial objective.

ESG-focused portfolios
Across the industry, there are many different approaches to managing ESG-focused portfolios. We consider the following strategies:

ESG leaders
Invest in companies that excel in managing ESG risks or taking advantage of financially material ESG opportunities.

ESG improvers and transitioners
Invest in companies that are actively enacting positive change in their own operations to address financially material ESG issues.

ESG solutions or enablers
Invest in companies that offer products and services that are essential to addressing financially material ESG issues.

Firm-wide exclusions policy

Except as noted below, the firmwide exclusions generally apply to all Janus Henderson Funds and discretionary segregated mandates. They do not apply to index and certain other derivatives or passive portfolios (including ETFs) intended to track a benchmark.

Issuers excluded
A direct manufacturer of and / or minority shareholding of 20% or greater in a manufacturer of:

• Cluster munitions
• Anti-personnel mines
• Chemical weapons
• Biological weapons

Classification of issuers is primarily based on activity identification fields supplied by our third-party ESG data providers. This classification maybe subject to an investment research override, following approval by the ESG Oversight Committee (ESGOC), in cases where sufficient evidence exists that the third-party field is not accurate or appropriate.

In any scenario where a portfolio position is identified as not meeting this exclusion criteria for any reason (legacy holding, transition holding, etc.) the portfolio manager shall generally be granted 90 days to review or challenge classification of the issuer if appropriate. After this period, in the event an investment research override is not granted, divestment is required under normal market trading circumstances.

Cannabis related issuers
To ensure Janus Henderson complies with regional legal and regulatory obligations ‘Cannabis-Related Issuers’ (CRI) may be excluded where an issuer’s revenue from cannabis related activities is understood to constitute more than 5% of their total revenue. A permissibility assessment is undertaken that gives consideration to various factors, including, without limitation:

• Domicile of Janus Henderson Fund;
• Domicile of Janus Henderson Fund Manager, including any sub-delegations;
• Domicile of the CRI; and
• Type of cannabis business operation, product, or activity conducted by the CRI.

Exceptions investing in CRI more broadly may be permitted following request to, and approval from, the ESGOC. All exceptions to this Policy requirement must be suitably documented with the accompanying rational.

Responsibility Team

The central Responsibility Team (the “team”) is a specialised in-house group focused on ESG data analysis and research, governance, ESG company and thematic engagement, and proxy voting and advisory services that serves as a resource for all our investment desks. They play a leading role in working with investment desks to enhance their ESG integration processes and externally leading our active participation in numerous responsibility initiatives. Fundamental, bottom-up research has been at the core of our investment process for more than 45 years and this partnership leads to enhanced research and decision-making by marrying the sector and industry expertise of the investment teams with the responsibility skills of the Responsibility Team.

In December 2022, we appointed Michelle Dunstan, an experienced leader in Responsibility strategy and responsible investing, as Chief Responsibility Officer (CRO) to oversee our Responsibility strategy. To emphasise the importance of our responsibility efforts and embed them across our entire firm, the CRO reports directly to the CEO, provides quarterly reports to our Board of Directors on established metrics and targets, and sits on the firm’s Strategic Leadership Team.

In 2024, we continued to add specialist resources to our central Responsibility Team to better align resourcing with our strategic priorities. As of year-end 2024 the Responsibility Team has 28 dedicated team members working as responsibility subject matter experts partnering with investment teams and firmwide colleagues. The team sits on the investment floor and is easily accessible to investment professionals. The Responsibility Team is centred around four focus areas:

Our Responsibility Strategy and Operations pillar supports our investment and non-investment teams in four areas -ESG Data and Analytics, Content and Learning (including the development of training, reports, client responses, external communications, and ESG thought leadership), Regulations and Risk (collaborating with Regulatory, Risk, Compliance, and Legal on relevant regulatory requirements / disclosures), and Corporate Sustainability (development and support of our corporate environmental strategy and execution).

Our Responsible Investment and Governance pillar provides direct support to our investment teams. The focus of this partnership is on equipping and supporting our analysts and portfolio managers to do what they do best: research industries and securities to select the most attractive candidates for inclusion in our portfolios. Our team will partner with the investment teams to deliver ESG training, support on developing frameworks to identify financial material ESG risks and considerations, planning and conducting engagements, supporting research on issues that can impact cash flows or valuation, and advising on proxy voting.

Our Responsibility Client Solutions pillar focuses on partnering with our product, distribution, and investment teams to enhance existing portfolios and deliver new portfolios to clients across varying levels of responsibility needs, from robust integration to ESG-focused strategies. They also partner with investment desks to continuously evolve our integration capabilities, including developing and refining integration frameworks that inform research, stewardship, and portfolio construction. Furthermore, the team also contributes to thought leadership content and conducts training on various responsibility topics.

Our Diversity and Community Relations pillar focuses on our core value of “Diversity Improves Results” and community relations. They are committed to creating an inclusive environment that promotes true meritocracy, cultural awareness, and respect.

To support our core value of “Diversity Improves Results” and community relations, we have a DEI Committee that is comprised of representatives from the Executive Committee and Senior Management. The Committee sets the firm overall DEI strategy, monitors progress and allocates budgetary resources. We also have a dedicated regional council. The councils are responsible for implementing our strategy at the regional level. Our Employee Resource Groups (ERGs) lead on championing grass-roots efforts led by employees and support our overall diversity, equity and inclusion goals. Our ERGs offer colleagues with common interests an opportunity to meet on a regular basis and discuss how they can make Janus Henderson a more inclusive workplace for all.

We leverage our ERGs to ensure that policies and communication are inclusive by allowing them an opportunity to review communication and messaging as needed and help design the curriculum to ensure it was relevant for our employees. Our ERGs also support with celebrating important events such as International Women’s Day, PRIDE, Remembrance Day, Black History Month, and more.

Goals for Responsibility Team and Chief Responsibility Officer

The role and goals of the Responsibility Team and Chief Responsibility Officer oversee the areas of our three-pronged approach to ESG.

• The first is our own corporate responsibility. We engage with our investee companies and encourage them to adhere to high corporate responsibility standards as a key driver of financial performance. Consequently, we believe our own standards should mirror those expectations.

• The second is ESG integration. We believe integrating financially material ESG factors is instrumental to fulfilling our fiduciary duty to our clients. Global environmental challenges such as climate change, biodiversity loss and pollution, and societal issues such as wealth and income inequality, access to education and healthcare, and cyberwarfare represent substantial long-term material risks to investor portfolios. We believe integrating these financially material ESG considerations into our investment decisions and stewardship processes allows us to better manage these risks to achieve the best outcomes for our clients.
  We also believe that ESG integration must be robust and incorporated into each appropriate stage of the investment management process, including idea generation, research and forecasting, engagement, investment decisions, and stewardship. We leverage our deep history with fundamental research to approach integration in a thoughtful, practical, research-driven, and forward-looking manner.
  For engagement, we engage for both insight – to understand company strategies and actions and leverage that information in our investment process, and we engage for action (outcome-oriented engagements), to encourage companies to take decisions that are in the best interest of long-term sustainable cash flows.

• The third is our JHI Brighter Future Funds. For clients who want to invest for a purpose beyond risk and return, we continue to build our suite of ESG-focused strategies and initiatives that go above and beyond integration to have ESG at their core alongside the primary financial objective.
  To accomplish this, the Responsibility team and Chief Responsibility Officer have five goals, as agreed upon by the Janus Henderson Group Board of Directors:
  • Enhance ESG insight and integration within investment teams
  • Offer clients a comprehensive, customized Responsibility experience
  • Systematize Responsibility data for enhanced insights and reporting
  • Adopt and embed a long-term strategic approach to addressing ESG Regulations
  • Extend strategic focus of Corporate Responsibility initiatives

The team’s four business lines are set up to accomplish these goals:

• Our Responsible Investment and Governance pillar provides direct support to our investment teams. The focus of this partnership is on equipping and supporting our analysts and portfolio managers to do what they do best: research industries and securities to select the most attractive candidates for inclusion in our portfolios. Our team will partner with the investment teams to deliver ESG training, support on developing frameworks to identify financial material ESG issues, planning and conducting engagements, supporting research on ESG issues that can impact cash flows or valuation, and advising on proxy voting.
• Our ESG Strategy and Operations pillar supports our non-investment teams in four areas - Strategic Initiatives (including responsible investing strategy, policy, and partnerships), ESG Data and Analytics, Content and Learning (including the development of training, reports, client responses, external communications, and ESG thought leadership), and Regulatory/Operations (collaborating with Regulatory, Risk, Compliance, and Legal)
• Our Client Solutions pillar focuses on partnering with our product, distribution, and investment teams to enhance existing portfolios and deliver new portfolios to clients across varying levels of ESG needs, from robust integration to ESG-focused strategies.
• Our Diversity & Community Relations pillar is committed to fostering inclusion, promoting cultural awareness, and establishing equitable policies, benefits, and training that support our people, and our DEI goals, and community outreach and relations.

Our Chief Responsibility Officer (CRO) provides quarterly updates to the Governance and Nominations Committee on progress against a range of tangible metrics. These metrics include:

• Upholding strong corporate practices: Maintaining strong ESG scores; setting and achieving governance goals.
• People, Community, and Environment: Setting and achieving people goals (including diversity, equity, and inclusion targets); setting and achieving corporate environment goals (including Scope 1, 2, and 3 emissions targets).
• Enhancing ESG reporting and messaging: Credibly assessing and effectively managing risks of current and future ESG regulations and reporting requirements; developing credible and consistent firm-level ESG messaging.
• Building our brand for thoughtful responsible investing: Developing ESG thought leadership; improving external ratings (from PRI and other bodies) for our responsible investing practices.
• Enhancing ESG integration and development of new ESG strategies: Increasing prevalence and quality of ESG integration; increasing number of (and assets in) ESG-focused strategies.

Additionally, the CRO first presented a dashboard of ESG and climate metrics to the Janus Henderson Board at our July 2023 Board meeting (data pertained to 30 June 2023). The CRO has presented the same dashboard for each quarter since then.

Investment Team Resources Dedicated to ESG Investment Research Analysis

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Portfolio managers who manage Janus Henderson Investors Brighter Future Funds

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Responsibility Team

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Responsible Investment Policy Oversight and Governance

Board of Directors

While our Board of Directors has received updates on sustainability, climate and ESG issues in the past, oversight of Responsibility and Responsible Investing, including climate considerations, were formally put under the remit of the Governance and Nominations Committee of the Janus Henderson Group Board of Directors in 2023. The Governance and Nominations Committee has established tangible ESG and climate metrics and targets for both our operational and investment activities, Our Chief Responsibility Officer presents a quarterly update to the Governance and Nominations Committee on the metrics, progress against targets, and advancements on strategic Responsibility initiatives. In addition, the Chief Responsibility Officer conducts a Director education session for the Governance and Nominations Committee each quarter; this is a “deep dive” into an important ESG topic—which could include our own corporate responsibility practices or our responsible investing practices.

ESG Oversight Committee

Our ESG Oversight Committee (ESGOC), which reports to Janus Henderson’s ExCo, provides direct oversight of ESG investment-related matters. The ESGOC provides oversight over ESG investment processes including credibility and feasibility of ESG-related commitments in portfolio design, portfolio management, various ESG data and toolsets, as well as non-investments oversight over ESG processes including regulatory and client reporting standards, and ESG disclosure. The ESGOC is responsible for ensuring that the firm’s framework to manage ESG-related risks is adequate and effective. Specific duties include:

• Review of ESG-related metrics and commitments for new funds and mandates and changes to ESG-related commitments to existing mandates
• Review of ESG-related processes, systems, and resources in place for funds and mandates
• Review of output from ongoing ESG oversight controls monitoring of key ESG-related metrics and exceptions, as well as escalations of matters identified during the course of the monitoring, if any.

The ESGOC is chaired by our Chief Responsibility Officer with additional membership from Responsibility, Product, Investment Controls & Governance, Compliance, Financial Risk, and Legal.

Internal Audit

Janus Henderson has an independent internal audit function, which reports to the Janus Henderson Group Audit Committee. It is responsible for the internal audit of the firm’s worldwide activities. Internal audit operates a multi-year, risk-based audit plan that covers all aspects of the firm’s investment and stewardship activities, such as proxy voting. Internal Audit embeds ESG considerations in all relevant audits within its cyclical risk-based plan. In addition, Internal Audit includes thematic reviews, which in 2024 included a review of the ESG control framework with a focus on regulatory compliance. The findings of these internal audits are regularly shared with the Janus Henderson Group Audit Committee as well as other relevant boards.

Risk management functions

Our Operational Risk function provides support and oversight to each business function to ensure all operational risks are managed in accordance with the risk appetite statement of the firm. Climate risks associated with each operational risk are identified and analysed as qualitative scenarios. Corporate physical and transition risks are reviewed at least annually and reported in a formal corporate Climate Risk Report to the Janus Henderson Group Risk Committee (including escalations of matters identified during the period, if any).

Our Financial Risk team is an independent function reporting directly to the Chief Risk Officer. Its activities include market risk oversight, liquidity risk monitoring and counterparty credit risk management. Further, the team reviews and challenges investment management in light of ESG-related risks— including climate risks—alongside traditional market risk metrics and embeds sustainability risk into the risk profiles of our funds, as appropriate. Beginning in 2023, the Financial Risk team further supports the investment desks in providing portfolio-level oversight of sustainability, climate, and ESG risks. Risk oversight meetings are held with investment desks regularly, with an agenda item to ensure climate-related portfolio risks have been identified.

Compliance

The Compliance team implements automated investment restriction controls within Janus Henderson’s order management system for ESG-related screening and supplements this approach with further controls for qualitative commitments. Additionally, the Compliance team reviews regulatory adherence to the investment policy via the execution of a risk-based monitoring plan. The Compliance team provides board and committee reporting on ESG regulatory matters and are members of the ESGOC.

Front Office Controls

The Front Office Controls & Governance team provide ongoing assurance that investment products are managed in line with documented sustainability commitments, where automated controls and/or third-party data are not available.

ESG Ratings and Recognition

We believe there is a strong link between sustainability issues and the companies that will grow and succeed going forward. This applies to us as an organisation, as well as the companies our investment teams actively engage with in their pursuit of long-term risk-adjusted returns for our clients.

Janus Henderson has been certified as a carbon neutral entity since 2007 by offsetting our corporate greenhouse gas emissions in accordance with The CarbonNeutral® certification. We continue to be certified as a CarbonNeutral® entity in 2024, including for emissions across our corporate Scope 1, 2 and a subset of upstream Scope 3, including business travel, waste, and homeworking. We have been an investor signatory of the Carbon Disclosure Project since 2000 and we are a registered supporter of the Task Force on Climate-related Financial Disclosures (TCFD) with our first report published in 2023. In 2024 we maintained high scores in our Principles for Responsible Investment (PRI) reporting covering the prior year through 30 June 2024.

Janus Henderson actively participates in a variety of independent ESG/CSR benchmarking exercises including with firms such as MSCI, Sustainalytics, DJSI, UN PRI, and CDP to evaluate the sustainability of our practices alongside our peers. As of November 2024, our firm received a AAA rating from MSCI. This rating keeps us in the top cohort of 7% of industry peers (which has shrunk from 10% last year), defined by MSCI as the 27 asset managers and custody banks in the MSCI ACWI index.

Janus Henderson Group is rated at the parent company level and continues to maintain the following ESG Ratings

• MSCI: AAA as of November 2024
• Sustainalytics: 16.8 / low risk as of December 2024
• CDP: C as at December 2024
• FTSE Russell ESG Scores: 3.9/5 as of June 2024
• ISS: C- ESG Corporate Rating (E&S ratings updated as of September 2024, G updated as of May 2024)

Further, in February 2024, Janus Henderson’s ESG commitment level rating was upgraded by Morningstar from Low to Basic, where many of our peers are ranked. This is a very important development as many clients look to these ratings as evidence of our ESG capabilities. Furthermore, any individual fund’s ESG rating cannot be more than one notch higher than the firm-wide rating, so this will enable ESG rating upgrades to ‘Advanced’ for some of our strategies.

The Responsible Investment Brand Index (RIBI™) is an index scale that evaluates more than 600 asset managers on their commitment to responsible investment and branding. In April 2025, RIBI™ rated Janus Henderson Investors "Avant-Gardist" for the second year in a row. This rating is their highest distinction, with only 20% of asset managers assessed achieving this category.

ESG Affiliations, Memberships, Initiatives and Certifications

In addition to being a founding signatory of the United Nations-supported Principles for Responsible Investment (PRI), Janus Henderson is involved in a wide range of ESG-related initiatives and working groups as a member, supporter or in an advisory capacity.

Our participation in industry working groups along with our sharing of insights and knowledge of ESG through our published materials reflects our status as an active proponent of sustainable investing.

For the full list of our ESG Affiliations, Memberships and Certification details please refer to the Affiliations section in our website: Responsibility-Related Affiliations at Janus Henderson - Janus Henderson Investors

In addition, we publicly support standard setters and industry groups who work with governments to implement stronger sustainability standards in the investment management industry. Where possible, we contribute to ESG policy and regulatory discussions through our response to consultations.

Thought Leadership

As part of our commitment to advancing the industry dialogue around ESG, we seek to make the thinking of our investment teams widely available to our clients, shareholders, and other stakeholders through a variety of content, including white papers, articles, podcasts, videos, and panel debates. As with our ESG research, we aim to publish content that contains thoughtful, practical, research-driven, and forward-looking insights.

In 2024, we generated 25 thought leadership and educational pieces on ESG topics. The insights included portfolio manager-specific views related to sustainable investment themes, including relevant topics such as responsible AI investing, the changing regulatory landscape, and our 2024 ESG Outlook.
In terms of specific themes and topics, we produced broader papers and debates on a variety of ESG issues, including methane emissions from the oil & gas industry, deforestation, the role of metals in decarbonisation, renewable energy, and electric and autonomous vehicles. We also published articles outlining our approach to ESG and natural capital investing.

For further information on Janus Henderson’s ESG capabilities, policies, engagement etc., please visit to the ESG Resource Library in our website: ESG Resource Library at Janus Henderson - Janus Henderson Investors.

Dialshifter

This fund is helping to ‘shift the dial from brown to green’ by…

SFT was born from a desire to create a “tech for good” portfolio, aligned with the team's core belief that technology is the science of solving problems and key to addressing global challenges, catalysing positive environmental and social change. This is embodied through our eight sustainable technology themes, aligned to the UN Sustainable Development Goals. We firmly believe businesses and investors have the ability – and the responsibility – to help steer our world onto a more sustainable path.

SDR Labelling:

Sustainability Focus label

SDR Literature:

• Consumer Facing Disclosure