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 (SFT) Strategy (the ‘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 thematic selection criteria lead the team to invest in businesses that contribute to the development of a more sustainable global economy 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.

Negative Screening – Companies on the wrong side of sustainable/ESG 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. We seek to avoid businesses that have products or operations directly associated with the following criteria:

Norms-based screening: United Nations (UN) Global Compact Principles and OECD Guidelines for Multinational Enterprises
All holdings are compliant with the UN Global Compact whose ten principles cover human rights, the International Labour Organization’s Declaration on workers’ rights, corruption and environmental pollution. This provides minimum safeguards for the investments in the Strategy. Janus Henderson Investors (‘Janus Henderson’ or the ‘Firm’) has implemented system-wide trading restrictions to prevent transacting in securities subject to applicable sanctions regimes, including those administered by the Office of Financial Sanctions Implementation (UK), the UN Security Council, the Office of Foreign Asset Control (US) and the European Union (EU), to the extent permitted by law. Restrictions are coded into Janus Henderson’s trading systems to prevent investment into sanctioned stocks and are updated in line with current sanctions regimes. Prior to an initial investment in a country/market, an internal analysis is conducted to identify any applicable regulatory risks (including UK, UN, US or EU sanctions) that may impact Janus Henderson or its clients. In terms of risk incident and controversies monitoring, all holdings are monitored and flagged in real time, and regular summaries are provided, using third-party data.

‘De minimis’ limits
Given the technology focus of the Strategy, no portfolio exposure with respect to the avoidance criteria is expected. However, there may be instances when we will apply a de minimis limit. A de minimis limit of 5% is a threshold above which investment will not be made and relates to the scope of a company’s business activity; the limit may be quantitative (eg. expressed as a percentage of a company’s revenues) or may involve a more qualitative assessment. De minimis limits exist because sometimes avoiding an industry entirely may not be feasible given the complex nature of business operations. In such instances, we will invest in a company only if we are satisfied that the ‘avoided’ activity forms a small part of the company’s business and when our research shows that the company manages the activity in line with best practices. In instances where we disagree with the third-party assessment, or where third-party data is lacking or of poor quality, our dedicated sustainability analyst will review and, where required, seek approval at our independent ESG Oversight Committee. Our positive and negative screening are expected to reduce the Strategy’s investable universe by over 20%.*

*As at 31 December 2025. Figure subject to change.

Please refer to the Investment Principles - JH Sustainable Future Technologies Fund for further details.

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 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 contribute to the development of a more sustainable global economy 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 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 Responsible Investment and Governance 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, and 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, and 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, and 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, and 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, and 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, and 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, and 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, and 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.

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), 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 thematic revenue alignment, organic growth potential, 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 company margins. We look for companies where we believe the management quality, growth rate or the sustainability of that growth rate is underappreciated. To fulfil our dual mandate, through in-house bottom-up fundamental research and proprietary forecasting, we seek to identify thematic alignment as well as unexpected earnings or cashflow growth as a core tenet of every investment case. Thematic alignment and ESG leadership is integrated into our proprietary revenue mapping and ESG ranking within our valuation framework.

The team analyses 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 six pillars of the team’s investment process, and each company is assessed on this basis. Thematic alignment analysis carried out by the dedicated sustainability analyst provides additional insight.

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

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 with a variety of valuation approaches used by sector specialists focused on future earnings and cashflow, all monitored by our proprietary master valuation framework. We also integrate sustainability and ESG criteria into our valuation assessment to help evaluate the appropriate premium/ discount to the market. Our proprietary master valuation framework monitors all our target prices, earnings momentum, and share price performance, while our Ranking Screen and ESG tool (ESGX) allows us to identify ESG indicators relevant to the valuation framework. Our ranking screen brings together a variety of valuation, growth, momentum, and quality metrics alongside ESG indicators to help identify new ideas, stocks which are lagging, or best in class within the sub-sector. Our white paper ‘The relationship between ESG factors and valuation within the technology sector’* provides us with empirical support for our process of integrating our ESG insights into valuation discipline and into our engagement approach. We believe that improving ESG standards have an important role in enhancing company valuation.

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 our proprietary materiality framework, 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. ESG Explore 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 ESG Explore, 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 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 outcome. 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. Based on this stock selection process the team assign 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 thematic alignment 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 proprietary ESG ranking screen and utilise ESG Explore 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.

Please refer to the Investment Principles - JH Sustainable Future Technologies Fund for further details.

Resources, Affiliations & Corporate Strategies:

As at 31 December 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 10 dedicated ESG experts embedded within numerous investment teams. Additionally, we have 15 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 December 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 achieve their risk and return objectives using ESG criteria, we have and continue to build our suite of JHI Brighter Future Fund strategies that have an ESG focus, 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 continue to remain a signatory to the Financial Reporting Council’s UK Stewardship Code, regarded as a benchmark in investment stewardship, as well as supporting Japan’s Stewardship Code, and broader initiatives around the world including the UN-supported Principles for Responsible Investment (PRI).

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 achieve their risk and return objectives using ESG criteria. To meet the needs of these clients, we have and continue to build our suite of JHI Brighter Future Fund strategies that have an ESG focus, alongside the primary financial objective..

Companies that have leading ESG practices
Invest in companies that excel in managing ESG risks or take advantage of financially material ESG opportunities.

Companies that are improving or transitioning
Invest in companies that actively enact positive change in their own operations to address financially material ESG issues.

Companies that provide ESG solutions or enable others
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.

Weapons (or Controversial Weapons) Exclusions
No investments in direct manufacturers of the below:

▪ Cluster munitions
▪ Anti-personnel mines
▪ Chemical weapons
▪ Biological weapons (‘non-conventional weapons’)

Further to this, investments cannot be made in issuers which invest in/have minority shareholdings of 20% or more in manufacturers of the above.

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 Group Fund;
▪ Domicile of Janus Henderson Group 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 rationale.

Implementation

Classification of issuers is primarily based on activity identification fields supplied by our third-party ESG data providers. This classification may be 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.

Responsibility Team History

We have had employees focused on ESG research, stewardship, etc. since 1991; typically embedded within the investment teams. In 2012, we formally created a separate Responsibility team, independent from the investment teams.

Responsibility Team
The central Responsibility Team is a specialised in-house group that brings together expertise in responsible investment and governance, ESG data and analytics, thematic research, engagement advisory, proxy voting, and regulatory strategy, partnering with and serving as a resource for 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.

Beyond investment support, the Responsibility Team drives strategic initiatives, develops new ESG products, provides bespoke client advisory, and leads corporate sustainability programs. They also represent the Firm externally through active participation in global responsibility initiatives and stewardship codes, reinforcing our commitment to transparency and long-term value creation.

Michelle Dunstan, an experienced leader in Responsibility strategy and responsible investing, is our Chief Responsibility Officer (CRO), overseeing 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.

Goals for Responsibility Team and Chief Responsibility Officer

Our Chief Responsibility Officer oversees the areas of our 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 achieve their risk and return objectives using ESG criteria, we have and continue to build our suite of JHI Brighter Future Fund strategies that have an ESG focus, alongside the primary financial objective. This can be evidenced by, for example, thematic selection criteria, commitments to beat a benchmark on specific ESG metrics, or targeting a positive environmental or social impact.

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 Responsibility insight and integration within investment teams
• Embed a long-term strategic approach to addressing ESG regulations. Systematise Responsibility data for enhanced insights and reporting▪
• Integrate our corporate responsibility strategy in broader corporate strategy. Offer clients a comprehensive, customised Responsibility Solution.

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

• Our Responsibility Strategy and Operations pillar oversees firmwide responsibility delivery by providing the data, infrastructure, regulatory coordination, and operational support that underpin investment decision-making, client outcomes, and corporate sustainability. They support our investment and non-investment teams in areas of ESG data and analytics, regulations and risk (collaborating with Regulatory, Risk, Compliance, and Legal on relevant regulatory requirements / disclosures), corporate sustainability (development and support of our corporate environmental strategy and execution), and public affairs.
• 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 financially material ESG risks and considerations, planning and conducting engagements, supporting research on issues that can impact cash flows or valuation, and advising proxy voting.
• Our Responsibility Client Solutions pillar focuses on partnering with our product distribution teams, 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. The team also contributes to the development of training, reports, client responses, external communications, and Responsibility thought leadership topics.

Beyond the three core pillars, in 2025, we introduced a new position designed to amplify the intersection of purpose and financial impact: the Brighter Future Strategist. The Team’s Brighter Future Strategist role helps connect Janus Henderson’s purpose, responsible investing priorities, and philanthropic initiatives in a way that is meaningful and accessible for clients. The Brighter Future Strategist works across investments, responsibility team pillars, brand, and client teams to strengthen Janus Henderson’s brand with clients and investors by championing the values that shape our business and define our future.

Our Chief Responsibility Officer provides quarterly updates to the Governance and Nominations Committee on progress against a range of tangible metrics, including science-based targets on our corporate Scope 1 + 2 and Scope 3 upstream emissions, metrics around reporting, thought leadership, and investment strategy development.

Responsible Investment Policy Oversight and Governance

Board of Directors

Oversight of Responsibility, including climate considerations, is part of the formal remit of the Governance and Nominations Committee of the Janus Henderson Group Board of Directors. The Group Governance Committee has established tangible ESG and climate metrics and targets for our operational activities. These metrics include setting science-based targets on our corporate Scope 1 + 2 and Scope 3 upstream emissions, and tracking our CDP score, as well as metrics around reporting, thought leadership, and investment strategy development. At the investment level, the Board receive metrics on how we integrate material climate factors in our research and engagement, our thought leadership, and in our investment strategy development. Our Chief Responsibility Officer, Michelle Dunstan, presents a quarterly update to the Group 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 Group Governance and Nominations Committee each quarter; this is a “deep dive” into an important Responsibility 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.

In 2024, our ESGOC successfully established our ESG Strategic Advisory Council, which sits under and supports the ESGOC, strategically by reviewing, challenging, and advising on firm-wide or investment-level ESG regulatory and non-regulatory developments, strategic priorities, pledges and partnerships, and other ESG matters requiring strategic input.

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 CarbonNeutral® company since 2007, and we continued to be certified as a CarbonNeutral® company throughout 2024, including for emissions across our corporate Scope 1, 2, and a subset of upstream Scope 3, including business travel, waste, and homeworking. To achieve this certification, Janus Henderson’s emissions inventory has been independently assessed, and we have provided financing to a range of emission reduction projects, supporting essential renewable energy, afforestation, and methane capture from landfill gas to offset our remaining emissions. These projects additionally deliver co-benefits for the environment and society in accordance with the United Nations Sustainable Development Goals (SDGs). Additionally, 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). In 2024 we maintained high scores in our Principles for Responsible Investment (PRI) reporting covering the prior year through 30 June 2024. Due to changes in the reporting structure, we elected to disclose only the mandatory PRI signatory reporting through June 2025; therefore we will not receive an updated PRI score until approximately November 2026, covering 1 July 2025 – 30 June 2026.

Janus Henderson actively participates in a variety of independent ESG/CSR benchmarking exercises including with firms such as MSCI, Sustainalytics, and CDP to evaluate the sustainability of our practices alongside our peers.

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

As at 31 December 2025, our Firm received a AAA rating from MSCI. This rating keeps us in the top 10% of asset management and custody bank industry peers.

• MSCI: AAA as of December 2025
• Sustainalytics: 16.8 / low risk as of December 2024
• CDP: C as at December 2024
• FTSE Russell ESG Scores: 4.4/5 as of June 2025
• ISS: C- ESG Corporate Rating (E&S ratings updated as of September 2025, G updated as of May 2025)

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 2025, we generated 28 thought leadership and educational pieces on responsibility topics. Our investment teams also produce papers on ESG investment approaches and relevant topics. The insights included relevant topics such as evaluating corporate transition plans, precision technology in agriculture, responsible mining, and human rights and supply chain management.

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…

Sustainable Future Technology 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. The dual mandate strategy focuses on delivering both financial returns and positive environmental and social benefits.

SDR Labelling:

Sustainability Focus label

SDR Literature:

• Consumer Facing Disclosure
• Quartlerly ESG, Sustainability & Climate Report