Sustainable, Responsible &/or ESG Policy:

Janus Henderson has been involved in managing Sustainability portfolios for almost 30 years and the US Sustainable Equity strategy was launched in 2021. At the heart of the approach is the belief that the best investment returns will be generated by companies which are providing solutions to environmental and social challenges. These companies should have attractive financial attributes such as persistent revenue growth and durable cash flows.

The Global Sustainable Equity (GSE) Team (the ‘team’) aims to outperform the market over the long term through creating a differentiated global equity portfolio of the best sustainability ideas. The team’s investment approach is explicitly low carbon and by incorporating environmental, social, and governance factors into their analysis they seek to construct a portfolio with a favourable risk profile.

Key Distinctions

• Investing with positive impact: environmental and social considerations are integral to the investment philosophy and process, from universe definition and idea generation through to fundamental analysis, engagement and portfolio management. A dedicated sustainability professional within the team enables deep integration of sustainability issues into investment process and enhances our ability to analyse issues from multiple angles.
• Deep investment resource: the dedicated GSE portfolio management team works in collaboration with Janus Henderson’s global equity research platform and draws upon the deep knowledge and domain expertise of the sector and regional teams.
• 30 years of Sustainability thought leadership: we have a long and successful track record in the consistent application of our sustainability framework – the GSE strategy was launched in 1991 and Hamish Chamberlayne, CFA has been managing the strategy since January 2012. We have been thought leaders on sustainability issues since the inception of the strategy and were founding signatories of the UNPRI in 2006.
• Explicitly low carbon: we consider 5 levels in our approach to low carbon investing. We believe this approach will be a significant source of alpha as the transition to the low carbon economy continues over the next decade and beyond.
  Hamish Chamberlayne, CFA has had training in climate change and has written a paper on the investment implications. The team have many years of experience in analysing, understanding and managing both climate risk and transition risk within portfolios (the GSE strategy has had this low carbon approach since inception in 1991).
• Continuous improvement: we have a philosophy of continuous improvement that applies both to ourselves and the companies we invest in. We are always looking to enhance our understanding of evolving sustainability issues and how to incorporate them into our investment process. Our portfolio management is driven by this philosophy.

Our Alignment with Sustainable Development

The guiding principle of our investment philosophy is: ‘Is the world a better place because of this company?’ and we always consider whether a company’s products contribute beneficially to the environment and society. Ten sustainable development investment themes help us identify long-term business opportunities. These have been informed by both the environmental and social megatrends that are pressuring the global economy, and by the UN’s 1987 Brundtland Report that defined sustainable development. Consequently, there is high alignment between our investment process and the UN Sustainable Development Goals (SDGs), and our portfolio contributes to all 17. Identifying companies that contribute towards the goals is inherent to our investment approach and we measure and report on this.

We believe there are a myriad of investment opportunities arising from the migration towards a more sustainable global economy, and that the best investment returns will be generated by companies that are on the right side of these. Looking for these long-term compounding characteristics and staying focused on long-term value not short-term valuation metrics, can generate exciting investment returns. We also believe there are substantial risks to companies and shareholder returns that come from factors such as asset obsolescence, regulatory risk, weak corporate cultures, or damaged franchises that are on the wrong side of ESG. While these risks can appear small in the short term, they also compound over time and can dramatically hurt company fundamentals.

Please refer to the Fund’s Investment Principles for further details.

Process:

Investment approach

There are four pillars to our sustainable investment process which incorporates both positive and negative selection criteria and includes both product and operational impact analysis. It is through this rigorous and repeatable stock-selection process that we believe we add value to our clients.

• Positive impact: Ten sustainable development themes guide idea generation and identify long-term investment opportunities.
• 'Do no harm’: Strict avoidance criteria are adopted. We will not invest in activities that contribute to environmental and social harm. This also helps us avoid investing in industries most likely to be disrupted.
• Triple bottom-line framework: Fundamental research evaluates how companies focus on profits, people and the planet in equal measure.
• Active management and engagement: We construct a differentiated portfolio with typically high active share (>90%). Collaborative, continuous and collective engagement 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.

Idea generation

Idea generation is derived from four ‘core’ megatrends that are pressuring the global economy: population growth, ageing populations, resource constrains and climate change.

The team believes that the defining investment issue of our time will be transitioning to a low-carbon and sustainable economy, while maintaining the levels of productivity necessary to deliver the goods and services that an ageing and growing population requires. Derived from these four megatrends, we identify ten environmental and social sustainable development themes. For every investment, the team must be able to identify at least one theme operating as a value driver to the business.

Investing with positive impact is inherent in our approach and integral to all investment decisions. All investments must demonstrate positive impact and we measure and report on this. We do this by measuring the proportion of portfolio revenues that are aligned with each of our ten positive sustainable development themes; by mapping our portfolio holdings against the United Nations Social Development Goals (SDGs); by reporting our carbon footprint, and by measuring our portfolio against a set of ESG KPIs that are informed by the Global Impact Investing Network’s IRIS metrics.

Do no harm, avoidance criteria

The negative impact on global prosperity from the cost of economic externalities is becoming increasingly recognised. The team seeks to avoid businesses involved in activities contrary to the development of a sustainable economy, believing these types of business to be at a higher risk from government regulation or disruption.

All holdings are compliant with the UN Global Compact, whose Ten Principles cover human rights, the International Labour Organisation’s declaration on workers’ rights, corruption and environmental pollution. Additional oversight is provided by Janus Henderson’s ESG Oversight Committee, an independent committee comprising senior figures from across Janus Henderson,
responsible for ensuring the strategy’s adherence to its exclusion criteria.

Fundamental and valuation analysis

The team is ultimately trying to identify businesses with long-term compounding characteristics, and with optionality upside, which are trading at discounts to their intrinsic value. Typically, the team is looking for companies with the ability to generate and compound long-term free cash flows, where the equity market is currently under-valuing those. There is a specific focus to the
financial analysis that the team do to identify intrinsic value.

The team looks for:

• The potential for multi-year revenue compounding
• A culture of innovation, that in turn drives that upside optionality
• Durable business models
• Greater predictability of revenues
• Consistency of margins and cash flows
• Strong balance sheets

The team also believes there are substantial risks to companies and shareholder returns from factors such as asset obsolescence, regulatory risk, the loss of key talent arising from weak corporate culture, or the loss of customers given the perception that a company operates on the wrong side of ESG. While these risks can appear small in the short term, they also compound over time
and can dramatically hurt company fundamentals.

We believe that the equity market often fails to see both the long-term value being created by some companies and underappreciates the long-term risks to others. We consider all of these factors as we think about a business’ fair value and stay focused on the potential for long-term value creation rather than on shorter-term valuation metrics.

Active portfolio construction and risk management

Every stock selected for the portfolio must fit at least one theme; but for the purposes of portfolio construction, there is no forced distribution of themes. Portfolio construction is driven by stock selection, with each stock assessed within the disciplined analytical framework.

The portfolio is constructed with the aim of generating attractive excess returns, but with a good level of overall risk diversification. The intention is to construct a high-conviction portfolio with high active share against the benchmark. There are some key principles to this.

• Portfolio construction is driven by stock selection, with each stock being assessed within the disciplined analytical framework. There are 3 levels of position size:
  • Substantial positions, of over 3% portfolio weight, are stocks with a superior combination of predictable revenue growth, financial strength and valuation upside. These positions typically account for 30-40% of the total portfolio.
  • Standard positions, of 2 to 3%, are the initial sizes for investments that meet all our portfolio entry requirements and have good liquidity
  • Small positions, of less than 1%, are less liquid investments which tend to be earlier in their life cycle, but where we see significant upside. These positions typically account for less than 5% of the total portfolio.
• The portfolio will be regionally balanced to avoid unintended country and currency risk. Emerging market investments will be limited to a maximum of 3% of the portfolio.
• The portfolio will comprise 30 – 50 equity investments. Every investment is selected on its own fundamental stock attributes but must contribute to overall portfolio fit and risk diversification.

The team believes that a high-conviction portfolio of stocks that align with the investment philosophy, which looks very different to the benchmark, but is managed with this high awareness of geographic, thematic and liquidity risk, can generate attractive risk-aware returns for our clients.

Sell discipline

Sales will be executed when the long-term investment thesis is impaired, or when corporate responsibility issues emerge and there is no possible resolution from engagement with the company. Additionally, a position will be sold if new information identifies a breach of the strategy’s avoidance criteria.

Engagement and reporting

Company engagement forms an important part of the investment process. We take an active approach to communicating our views to companies and seeking improvements in performance. We participate in various forms of engagement: 

• Collaborative engagement: coming together with a group of other institutional investors to engage with companies on a range of ESG issues
• Continuous engagement: working with companies on ESG issues that have long-duration and do not result in immediate outcomes
• Collective engagement: bringing together ideas and resources from a diverse range of stakeholders from outside the organisation to engage with companies on key issues.

On a quarterly basis we publish our ‘Positive Impact Report’ and our ‘Voting & Engagement Report’. The Positive Impact Report details how the portfolio holdings are having positive environmental or social impact. The Voting & Engagement Report details our corporate engagement and proxy voting activity.

On an annual basis we publish our ‘Annual Sustainability Report’ and our ‘Investment Principles Report’. The Annual Sustainability Report details our portfolio impact measurement. We review the UN SDGs and our positive impact for each SDG. This report also discloses our portfolio Carbon Footprint, measuring scope 1,2 and 3 emissions. The Investment Principles Report details our
investment philosophy, our definition of sustainability, and an in-depth description of our positive impact themes and avoidance criteria.

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…

Built 30 years ago, the four pillars of our sustainable investment approach remain as pertinent today as they were three decades ago. It is these pillars which have enabled the strategy to remain at the forefront of sustainable investing for so long; as knowledge of sustainability has progressed, our investment approach has blossomed all the while remaining rooted in the strategy’s core beliefs. We consider this to be integral to the strategy’s success.

SDR Labelling:

Sustainability Focus label

SDR Literature:

• Consumer Facing Disclosure link