Sustainable, Responsible &/or ESG Policy:

In order to achieve the investment objective, the Fund will employ a replication method that looks to invest as far as possible and practicable in the constituents of the Reference Index. The Fund intends to replicate the Reference Index by holding all of its constituent securities in a similar proportion to their weightings in the Reference Index.

The methodology of the Reference Index applies exclusionary criteria to exclude from the MSCI Europe Index (the “Parent Index”) securities that: 1) have not been assessed or rated by the Index Provider on the basis of MSCI ESG metrics (see further details below); 2) have faced severe or very severe controversies pertaining to ESG issues (including UN Global Compact violations) – defined as companies with an MSCI ESG Controversy Score of 0 or 1; 3) are involved (as defined by the Index Provider and detailed further in the methodology for the Reference Index) in any of the following business activities: controversial weapons, conventional weapons, civilian firearms, nuclear weapons, conventional and unconventional oil & gas, oil sands, shale oil, shale gas, uranium mining, thermal coal (including power generation and mining), thermal coal power, oil & gas power, nuclear power, oil & gas refining, fossil fuel reserves ownership, tobacco, recreational cannabis, adult entertainment, alcohol, gambling, GMOs and power generation from thermal coal, liquid fuel and natural gas; 4) have an MSCI ESG rating of BB or below; and 5) are categorised as investment trust companies.

The remaining constituents are then subject to an optimisation which has the aim of aligning the Reference Index to the objectives of the Paris Agreement by reducing the weighting of companies exposed to climate transition risks, maximising the weighting of companies with the highest exposure to climate transition opportunities and minimising the ex-ante tracking error relative to the Parent Index.

The Reference Index rebalances on a semi-annual basis (a “Rebalance Date”). At each rebalance, the weights of the securities are recomputed by applying the exclusionary criteria and optimisation approach described above, and changes to the components of the Reference Index are implemented at the next Rebalance Date. Between rebalances the index is reviewed on a quarterly basis screening out constituents that have breached the exclusion criteria but without applying a full rebalance. Given the climate focus of the Fund, a number of social indicators may not be relevant to the investment strategy of the Fund and as a result the methodology of the Reference Index may not specifically consider these indicators.

Where a previously eligible security subsequently ceases to meet the criteria of the Reference Index, or where the Fund acquires a security as a result of a corporate action, the Fund may continue to hold such security until such time that the security is removed as a component of the Reference Index at the next rebalance or review date.

The index methodology of the Reference Index includes good governance criteria whereby companies are assessed against indicators such as sound management structures, employee relations, remuneration of staff and tax compliance. Companies that are deemed not to meet good governance practices according to the methodology of the Reference Index will be excluded.

90% of the Fund’s NAV will be selected according to the binding elements of the investment strategy. A minimum of 80% of the Fund’s NAV will align with the sustainable investment objective of the Fund by contributing to the environmental objective of the Fund, meeting the do no significant harm criteria and good governance criteria. Up to 20% of the Fund’s NAV may not fully meet all the requirements to be deemed sustainable investments, according to Invesco’s PAI framework, as there may be certain social indicators not specifically considered by the Fund (those that are not relevant to the climate focus of the strategy). However, the investments will still be selected according to the criteria of the methodology of the Reference Index.

Up to 10% of the Fund’s NAV will be invested in financial derivative instruments for hedging and/or efficient portfolio management purposes and cash for ancillary liquidity purposes

Process:

The Fund passively replicates the Reference Index and the primary source of third-party data is the index composition as disseminated by the index provider. Invesco may also use third-party data from other sources besides an index provider. Invesco ensures that each index provider is a Benchmark Administrator on the ESMA register that is maintained in accordance with Article 36 of the Benchmark Regulation, or is in the process of applying for inclusion on the ESMA Register or approved by endorsement or recognition by a Member State competent authority.

Invesco performs due diligence on index providers and has internal controls to monitor constituent data (please refer to the sections “Data sources and processing” and “Due diligence”), however Invesco may not in all cases be able to verify the integrity of third party data used in the index construction. In placing reliance on external data providers there may be risks associated with errors in third party data. Such errors may be undetectable by either Invesco or the index provider and can result in holdings weightings that are inconsistent with the stated methodology of the index and/or the investment objective and/or policy of the fund. The Funds could incur unexpected costs as a result such errors, for which losses Invesco and external data providers, acting in good faith, will not be held liable.

Where errors in third party data are identified, as the investment objective of the Fund is to track the index, the Fund may continue to hold investments that are inconsistent with the stated investment policy, or sustainable investments of the Fund, until such time that the data is corrected or, where the error has impacted the composition of the Reference Index, until the index provider rebalances the Reference Index. This applies to ESG data which may not only impact the Fund’s holdings but also the reporting done by the Investment Manager on the Fund’s ESG characteristics as required under relevant regulation.

Resources, Affiliations & Corporate Strategies:

Created in 2013, Invesco’s dedicated Sustainable Investing Services (SIS) team and the Proxy Voting team are responsible for leveraging best practices globally in sustainable investing capabilities across Invesco including ESG integration, voting and engagement, supporting distribution teams with client engagement, and advising product teams on sustainability innovation.

Our Global SIS and Proxy Voting teams act as a centralised resource to guide, support and inform Invesco's investment teams on all work in this area. The teams are organized across five pillars:

• Client: Guides messaging and training for distribution teams, engages clients on ESG issues, and supports product strategy.
• Research: Conducts proprietary ESG research and collaborates with investment teams on engagements.
• Analytics: Manages ESG analytics, data vendor selection, portfolio screening and reviews.
• Operations: Project manages sustainability-focused initiatives and manages the scheduling and organization for the SIS team.
• Proxy: Provides guidance on governance issues and supports development of our PROXYintel voting platform and Global Proxy Voting Policy.

The combined SIS and proxy Voting teams includes 36 ESG professionals (as at 30 June 2025) located in North America, Asia Pacific, and EMEA who provide localized support and analysis to our investment teams across the globe. 

Our sustainable investing services professionals collaborate closely with these investment teams, providing support, insights and analysis while investment teams maintain discretion on portfolio decisions. Our governance structure enables oversight and accountability through the ESG Steering Committee, while allowing our investment teams to integrate sustainable investing approaches tailored to their asset classes and styles. 

As shown in the following organizational chart, the combined team comprises five pillars to support sustainable investing efforts across specific functions firm-wide. The team's geographic structure also ensures that most Invesco teams have an appropriate local contact. The ESG Steering Committee, asset class-specific investment teams, and firm-wide functional units also collaborate with SIS team members from each of the five pillars. 

Source: Invesco as of 30 June 2025. For illustrative purposes only.

Each investment team has a unique approach to incorporating sustainable investing considerations, as defined in its investment process and appropriate for the respective asset class. To support this effort, Invesco has dedicated specialists and champions within individual investment teams across the globe. These individuals are closely connected with the SIS team and formally collaborate via the ESG Steering Committee.

Governance oversight structure

Managing risk is an integral part of our investment culture at Invesco, and it starts with the recognition that everyone plays a role in risk management. Built with multiple lines of defense, our risk management approach seeks to ensure that our managers adhere to best practices. The goal is for portfolios to perform as expected and for clients to feel confident in their investment.

Investment teams

We believe the best outcomes are achieved through distinct investment teams across the globe, with discrete investment perspectives, operating under a disciplined philosophy and process. To support the unique needs of each investment team, each one deploys a robust risk management framework that is tailored to its investment process and is owned by its CIO. Each of our teams uses its framework to thoroughly assess the risk and return characteristics of each individual security and carefully calibrates the overall risk level of the portfolio when these investments are combined. Teams incorporate environmental, social, or governance related considerations where relevant or required to achieve portfolio objectives. Investment team leaders have responsibility for overseeing the implementation of investment strategies including those with ESG related objectives or incorporating ESG factors.

Multiple groups within Invesco

At each step in the process, the investment teams are provided with global expertise and support that enhances their risk management efforts. The following groups provide oversight of the investment teams to make sure they are operating within best practices as well as their stated objectives:

• Investment Risk Management is responsible for identifying, measuring, and monitoring appropriate portfolio risks to ensure that each portfolio is managed as intended
• Global Performance delivers customized portfolio performance analysis and attribution reporting that facilitates the Investment Risk evaluation of whether ex-post performance results are aligned with ex-ante risk expectations
• Global Compliance monitors pre- and post-trade compliance and performs other fiduciary assurance functions
• Other governance structures that assure best practices include the Global Trade Operations Committee, the New Instrument Committee, the Pricing Committee and the Proxy Committee

Senior leaders, independent boards and audit teams

Oversight is critical. The following groups provide a high-level review of the entire process:

• The Invesco Performance and Risk Committeeis composed of senior leaders who review risk and performance issues and monitor progress against the firm-wide strategic priority of achieving strong investment performance.
• Internal Audit provides end-to-end process review to identify any control gaps and execution challenges.

Given the importance that Invesco places on ESG at an investment level, Invesco has a governance structure across multiple dimensions, which enables oversight and accountability for effective stewardship.

Invesco’s Sustainable Investing Services Team acts as a global resource, responsible for investment team support and analysis related to ESG risks and opportunities, voting and engagement, supporting the distribution teams with client engagement, and advising product teams on ESG innovation, while investment teams maintain discretion on portfolio decisions. The team comprises professionals located across three regions: North America, Asia Pacific and EMEA. The team is organized across four pillars that define their major responsibilities: Client, Research, Proxy and Analytics.

The ESG Executive Steering Committee (ESG Executive Steerco) establishes strategic direction for and implementation of ESG related investment management initiatives at Invesco. The Committee is composed of representatives from Investments, Distribution, and many functional areas. It provides direction for resource allocation and operational implementation while facilitating communication across the firm. The Committee aids in fostering global collaboration on ESG issues, enabling us to benefit from diverse perspectives and maintain consistent standards. Alongside various cross-functional working groups, it encapsulates our inclusive approach to ESG, ensuring a purposeful, holistic strategy that aligns with client objectives.

We have created a variety of working groups across the organization in support of delivering ESG related investment capabilities. Some groups are tasked with delivering on a specific initiative or facilitating collaboration across an asset class or region. Others are designed for providing broad communication about current themes or regulation, tools or resources such as data, or they focus on evergreen priorities including proxy voting.

Invesco's Global Invesco Proxy Advisory Committee is guided by our philosophy that investment teams should manage proxy voting. It is a global investments-driven committee comprised of representatives from various investment management teams and chaired by the Director of Proxy Voting and Governance. The committee provides a forum for investment teams to monitor, understand and discuss key proxy issues and voting trends within the Invesco complex, to assist us in meeting regulatory obligations, and to consider conflicts of interest in the proxy voting process.

Assurance

Internal Audit prepares a risk-based audit plan at least semi-annually based on its assessment of the risks presented by various activities within the firm. The Department begins by determining and closely examining the universe of Invesco’s functional areas and entities, engaging in discussions with responsible parties and various assurance functions, reviewing market and industry developments, reviewing discussion topics raised by risk management committees, and considering regulatory expectations. 

Each item in the universe is given a ranking of Critical, Major, Moderate or Minor risk that accounts for both the likelihood a particular risk event could occur and the associated impact to the organization. Determination of the appropriate risk ratings involves an evaluation of many factors including but not limited to: Financial, Legal/Regulatory, Reputational, Operational, Customer or Client, and Market Detriment impacts.  

During this process, other assurance reviews are also considered. Internal Audit uses the overall risk assessment scores noted above, along with the regulatory requirements, guidance and feedback from the Audit Committee and senior management, to preliminarily assess whether a process should be considered for inclusion in the audit plan. Based on the result of risk assessment, ESG related matters may be identified for audit coverage as part of the audit plan

Additionally, the Global Compliance department's annual testing plan seeks to assess compliance in key risk areas, avoiding duplication of testing and considering other control reviews, including internal audits. Our Compliance Monitoring team seeks to apply testing standards consistent with regulatory expectations in each region in which Invesco operates, and reports findings to senior management of Compliance and other impacted business functions. For example, in 2020 the Compliance Monitoring team conducted an advisory review of proxy voting in North America. The purpose of this review was to provide guidance and recommendations around the region's proxy voting process, to evaluate whether policies and procedures were reasonably designed and to determine how effectively the controls in place comply with regulations.

Membership of other ESG/RI associations

Invesco is an active member and supporter of several external organisations, largely via our global investment teams. Following is a representative list of current affiliations.

A member of:

• 30% Club Japan Investors Group
• Asian Corporate Governance Association (ACGA)
• Asia Investor Group on Climate Change (AIGCC)
• Better Building Partnership (BBP)
• Carbon Disclosure Project
• Climate Bonds Initiative
• Corporate Responsibility Interface Center (CRIC) (DACH countries)
• Council of Institutional Investors (CII) (US)
• Farm Animal Investment Risk & Return Initiative (FAIRR)
• Global Real Estate Sustainability Benchmark (GRESB)
• EFAMA Sustainable Finance Committee
• ESG Disclosure Study Group (Japan)
• Hong Kong Green Finance Association (HKGFA)
• IFRS Advisory Council (oversees ISSB – successor to SASB)
• Investment Company Institute (ICI) (ICI Fund Disclosure Working Group, ICI Global ESG Task Force, and ICI Proxy Issues Working Group)
• Investment Association (UK)
• Investor Forum (UK)
• Institutional Investors Group on Climate Change (IIGCC), including Net Zero Investment Framework working group
• Investment Management Education Alliance (IMEA)
• Ireland Central Bank group (Invesco Investment Management Limited) 
• Irish Funds ESG Legal committee
• One Planet Asset Managers
• Quoted Companies Alliance (QCA)
• Responsible Investment Association (RIA) (Canada)
• Responsible Investment Association Australasia (RIAA)
• Task force on Climate-Related Financial Disclosures (TCFD) (Supporter and Discloser), TCFD Consortium
• Transition Pathway Initiative
• Task force on Nature-Related Financial Disclosures’ (TNFD) Forum
• UK Sustainable Investment and Finance Association (UKSIF)

A signatory to:

• Principles for Responsible Investment (PRI)
• EFAMA Stewardship Code
• Indian Stewardship Code
• Japan’s Stewardship Code
• UK Stewardship Code
• Net Zero Asset Managers Initiative

Additionally, GRESB provides the basis for the reporting, scoring and peer ranking of Invesco Real Estate's (IRE’s) ESG management and policies:

• IRE has submitted data to GRESB since 2012 and has been a GRESB member since 2014.
• In 2024, six IRE-managed strategies achieved five out of five Green Stars, placing them in the top 20% of all global submissions in 2024.

Source: Invesco as at 30 June 2025.

Invesco is committed to adopting and implementing responsible investment principles in a manner that is consistent with its fiduciary responsibilities to clients. We have a client-centric approach to responsible investing which focuses on customising solutions to client needs and objectives. Therefore, we do not apply a single, top-down, firm-wide responsible investing policy or process, instead, our investment teams implement policies or processes tailored to their asset classes, investment styles and client objectives. Where appropriate, sustainable and responsible investing policies are applied on a product-by-product basis in alignment with regional regulatory or client requirements.

We believe this approach is better than a one-size-fits-all methodology and allows us to provide a range of sustainable investing capabilities that support our clients in meeting their various objectives.

While we do not have a specific firm-wide responsible investing policy in the strictest definition, we do have a number of sustainability-related policies, statements and reports at the firm level which in aggregate lay out a high-level vision for responsible investing. These are listed below.

• Investment Stewardship Report outlines Invesco's accomplishments, reaffirming our commitment to global stewardship and detailing how our endeavours reinforce this core mission.
• Invesco’s Policy Statement on Global Corporate Governance and Proxy Voting describes Invesco's commitment to responsible investing and proxy voting, as well as the good governance principles that inform our approach to engagement and voting at shareholder meetings.

Invesco's Task Force on Climate Related Financial Disclosures (TCFD) Report seeks to build on our past experience and provide a comparable, investor-relevant disclosure on our activities and capabilities in climate-aware investing.

SDR Labelling:

Not eligible to use label (out of scope)

SDR Literature:

• Sustainability related disclosure