Sustainable, Responsible &/or ESG Policy:

Construction of the Fund

The Fund consists of three investment sub-portfolios: global equities, UK equities and fixed income. The sub-portfolios have the following approaches:

Global equities
The global equity sub-portfolio is managed using the same investment approach as Janus Henderson Investor's (‘Janus Henderson’ or the ‘Firm’) Global Sustainable Equity strategy which applies ‘positive selection criteria’. This investment approach seeks to invest in businesses that have products or services that contribute to the development of a more sustainable global economy, through their revenue alignment with ten environmental and social themes. Examples of themes identified include efficiency, cleaner energy, water management, environmental services, sustainable transport, sustainable property & finance, safety, quality of life, knowledge & technology and health. Full details on this sub-portfolio’s approach can be found in the Global Sustainable Equity Investment Principles document which is available on www.janushenderson.com.

UK equities
The UK equity sub-portfolio is managed using the same investment approach as Janus Henderson's UK Responsible Income strategy. This strategy seeks to identify UK companies with attractive longterm business models offering the potential for good dividend growth and capital returns over the long term. As part of the UK Responsible Income Fund’s investment process the portfolio manager will consider the effect of material ESG issues on the long-term attractiveness of companies. The strategy avoids companies that the portfolio manager considers to be involved in business activities and behaviours that may be environmentally and/or socially harmful. Full details on this sub-portfolio’s approach can be found in the UK Responsible Income Investment Principles document which is available on www.janushenderson.com.

Fixed income
The fixed-income sub-portfolio seeks to provide a return from a combination of income and capital growth over the long term. The responsible investment approach of the Fund seeks to invest in G7 government debt and global company bonds by incorporating ESG factors in investment decisions. This includes investment in labelled bonds, such as Green, Social and Sustainability Bonds, which are any type of bond instrument where the proceeds will be exclusively applied to eligible environmental and social projects or a combination of both. The sub-portfolio seeks to avoid companies that the portfolio manager considers to be involved in business activities and behaviours that may be environmentally and/or socially harmful. Further details on this sub-portfolio’s approach can be found throughout this document.

Environmental and social avoidance criteria
The investment approach of the Janus Henderson Global Responsible Managed Strategy (the ‘Strategy’) is primarily one of bottom-up security selection, operated within the ESG investment framework and avoidance criteria parameters of the Strategy.

Note: Avoidance criteria for the global equities sub-portfolio differ from those applied to both the UK equities and fixed income sub-portfolios, as further outlined below. In order to minimise exposure to business activities and behaviours that may be environmentally and/or socially harmful, the portfolio seeks to avoid businesses that have products or operations directly associated with the following criteria (subject to the notes and de minimis limits explained below)1:

Source: Janus Henson Investors, as at 31 December 2025.
1 We also seek to avoid companies operating in contentious industries which have a high degree of negative environmental or social impact unless the company is taking action to mitigate negative impacts. Examples of contentious industries include cement, mining, and timber.
2 3 ’R’s: Refine experiments to ensure suffering is minimised. Reduce the number of animals to a minimum. Replace animals with alternative techniques.
3 This exclusion extends to forward contracts on agricultural commodities.

In addition to the avoidance criteria, all holdings in the Strategy are compliant with the UN Global Compact Principles and the Organisation for Economic Co-operation and Development (OECD) Guidelines for Multinational Enterprises4. The UN Global Compact’s ten principles cover human rights, the International Labour Organisation’s declaration on workers’ rights, corruption, and environmental pollution, while the OECD guidelines cover a range of issues to including but not limited to employment, bribery, disclosure, and competition.

4 The OECD Guidelines for Multinational Enterprises are recommendations addressed by governments to multinational enterprises operating in or from adhering countries. They provide non-binding principles and standards for responsible business conduct in a global context consistent with applicable laws and internationally recognised standards.

Additional binding commitments (The following criteria applies across the whole portfolio)
We believe that the carbon intensity of the Strategy is an appropriate indicator of environmental sustainability and so commit to maintaining it at least 25% below the Strategy’s investment universe.

The ‘investment universe’ is the composite index: ‘50% MSCI World ex UK, 25% FTSE All-Share Index, 12.5% Bloomberg Barclays Global Aggregate Corporate Unhedged GBP, and 12.5% Bloomberg Barclays Sterling Aggregate Unhedged GBP’.

For the global equity allocation of the Strategy only, the Investment Manager aims to maintain a weighted average exposure to companies with notable ESG controversies that is below the MSCI World Index. Full details are available in the strategy’s Investment Principles document on www.janushenderson.com.

De minimis limits
Where possible, we will seek to achieve zero exposure in respect of the avoidance criteria. However, there may be instances when we will apply a de minimis limit. A de minimis limit 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 (e.g. 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 practice as monitored by MSCI.

When the activity relates to a company’s revenues, unless otherwise stated below, we use a 5% or 10% threshold, unless otherwise stated. When the activity relates to a company’s operations, we will seek to gain comfort that the company is taking action to improve its performance or is managing it in an exemplary fashion as measured by the monitoring of controversies. Any company with a persistent record of misconduct will be excluded unless there is clear evidence of significant progress.

The Strategy may invest in companies that would be excluded by the screens described above if the investment manager believes, based on its own research, and as approved by its ESG Oversight Committee, that the third-party data used to apply the exclusions is insufficient or inaccurate. Exclusionary screens are applied to direct investments (excluding government bonds) using third-party data at the point of investment and are monitored on a continuous basis. If an investment becomes ineligible based on exclusionary screens it will be divested within 90 days.

Janus Henderson has appointed specialist company, MSCI, to provide the environmental and social avoidance criteria screening of potential investments. An investee company must pass these screens or be approved by the ESG Oversight Committee to be eligible for the Strategy.

ESG investment framework

Assessment of the risks and opportunities stemming from environmental, social, and governance (ESG) issues forms part of our investment due diligence. We believe that companies with effective management strategies to address material ESG issues are more likely to reliably generate shareholder value.

As part of our analysis, we identify and prioritise the issues we deem to be the most financially material to the investment case. These vary from company to company according to the sector and industry. We define materiality as the potential of an issue to significantly impact the short- or long-term financial performance of a company. We look at whether a company is willing or able to manage and mitigate its material ESG issues / factors, how it performs in its peer groups, its exposure to controversies and its approach to climate change. We also consider other issues that have the potential to effect impact stakeholder groups beyond the shareholder, such as society, the environment, and the world around it.

Factors that may be considered include but are not limited to:

Identifying companies with good governance practices is fundamental to our investment process. We take factors such as the alignment of interests between shareholders and management, the strength of relations with stakeholders, and the management of environmental and social risks all as evidence of good governance practices.

At the Fund level, we monitor quantitative data on carbon emissions and climate scenario analysis. We also assess qualitative factors such as whether companies are measuring and reporting carbon emissions and whether they have set targets to manage these. As a result, and given the Fund’s exclusion of high emitting sectors, it is expected that the Fund’s carbon characteristics, as measured by third party provider MSCI, will be lower than if this approach was not applied.

We make use of both internal resources and external research and data providers. Internal resources comprise specialist sustainability analysts within various investment teams and Janus Henderson’s central Responsibility Team. Our principle external ESG data provider is MSCI, however, the Firm subscribes to and uses a number of specialist ESG research and data providers including: MSCI, Sustainalytics, ISS, Bloomberg, and RepRisk These providers are selected and monitored by the central Janus Henderson Responsibility Team.

The investment teams share ESG research produced in-house by our analysts across our proprietary centralised research platforms eQuantum and Quantum. These embed our ESG data tool, ESG Explore (ESGX), which contains comprehensive ESG data and analysis at both an individual stock and portfolio level, provided by MSCI. ESGX is designed to empower our investment teams to make informed investment decisions, enabling them to align portfolios with financially material ESG and climate considerations It currently features modules on ESG ratings, climate metrics (including climate scenario analysis and implied temperature rises), controversial business involvement, regulatory indicators and proprietary engagement data.

Collaboration with the central Responsibility Team

The integrated ESG approach to our investment decisions is further enhanced by collaboration with the central Responsibility Team, which comprises four pillars:

Equity and credit analysts, as well as portfolio managers, partner with the Responsibility Team analysts to work on joint engagement and leverage their ESG research. This can help generate ideas, increase transparency around ESG risks and challenge portfolio positioning.

Engagement

Stewardship and a commitment to good governance is an integral part of Janus Henderson’s active approach to investment management. The primary route for engagement is the regular meetings analysts and portfolio managers have with the issuers in which they invest, of which we hold thousands each year. Meetings can incorporate a wide range of topics, including strategy, capital allocation, performance, risk, management succession, board composition, corporate governance and environmental and social issues. We classify engagements as either:

Engagement for insight. The goal is to understand an issuer’s ESG strategy and actions and incorporate this into our decision-making.

Engagement for action. These are outcome-oriented, where we encourage issuers to take decisions that we believe are in the best long-term interests of bondholders.

Thematic engagements are chosen based on their relevance and potential to enhance understanding of financially material ESG factors within sectors. Top-down themes reflect client interests and key market and societal ESG trends, such as decarbonisation, water scarcity, decent work (diversity, equity and inclusion) and business ethics. This is typically cross-collaborative with equity colleagues and aligned with the Responsible Investment and Governance (RI&G) Team. Credit analysts additionally based on bottom-up considerations, triggered by their ongoing credit analysis.

Voting
Ultimate voting authority rests with the portfolio manager of each sub-portfolio, who is responsible for ensuring that votes are exercised in the best interests of clients, with ESG factors an important consideration where relevant. The portfolio managers are supported by the central Responsible Investment and Governance team, who work closely with investment teams to help analyse voting related issues. With regards to voting and company engagement, the portfolio manager considers certain core principles such as disclosure, transparency, board composition, shareholder rights, audit and internal controls, and remuneration. A key element of the approach to proxy voting is to support these principles and practices and foster the long-term interests of shareholders.

Given the Strategy’s responsible investment process incorporates environment, social, and governance factors in investment decisions, there will be relatively few shareholder proposals on ESG issues for the companies held in the strategy. We aim to support shareholder proposals on ESG factors for portfolio holdings following our approach to voting and engagement outlined within this document.

ESG metrics and engagements are published in the Strategy’s semi-annual / annual ESG, Sustainability and Climate report which is available at: Janus Henderson Global Responsible Managed Fund Annual ESG, Sustainability and Climate Report 2025.

Process:

The portfolio management team (the ‘team’) work closely with the broader Global Sustainable Equities Team and with the Firm’s Responsible Investment and Governance Team, part of the central Responsibility Team.

The Responsible Investment and Governance Team focuses on ESG data analysis and research, governance, ESG company and thematic engagement, proxy voting and advisory services that serves as a resource for all our investment desks. The team delivers 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.

Investment approach

The three sub-portfolios have the following approaches:

Global equities

The global equities sub-portfolio is managed using the same investment approach as Janus Henderson's Global Sustainable Equity strategy which applies ‘positive selection criteria’. This investment approach seeks to invest in businesses that have products or services that contribute to the development of a more sustainable global economy, through their revenue alignment with ten environmental and social themes. Examples of themes identified include efficiency, cleaner energy, water management, environmental services, sustainable transport, sustainable property & finance, safety, quality of life, knowledge & technology, and health.

The four pillars of our sustainability-driven investment strategy
We see four key elements to an investment approach based on sustainability. Often there are conflicts between environmental and social sustainability, and our approach seeks to address this by using both positive and negative (avoidance) investment criteria and considering both the products and operations of a business. Company engagement and active portfolio management are essential features of any true sustainable investment strategy.

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.

• Thematic revenue alignment: ten environmental and social investment themes guide idea generation and identify long-term investment opportunities.
• Avoidance criteria: we will not invest in activities that contribute to environmental or social harm. This also helps us avoid 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 (>85%). Collaborative, continuous, and collective engagement is a key aspect of our process.

Environmental and social investment themes
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 (resource constraints, climate change, aging population and population growth), we identify ten environmental and social investment themes. Examples of these themes the investment manager has identified include clean energy, efficiency, environmental services, sustainable transport, water management, knowledge & technology, health, safety, safety, sustainable property, and finance and quality of life. For a company to be eligible for the portfolio at least 50% of its revenues will be aligned with at least one of these sustainable development themes.

Fundamental and valuation analysis
The team have a rigorous process the fundamental research process which is looking at both ESG factors and also financial factors in an integrated fashion. The team ultimately analyses every company on the basis of the ‘3Ps’ of their ‘triple bottom line’ framework: how they generate Profits, how they impact People; and how they impact the Planet.

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.

UK equities

The UK equities sub-portfolio is managed using the same investment approach as Janus Henderson's UK Responsible Income strategy. The strategy is actively managed with reference to the FTSE All Share Index, which is broadly representative of the companies in which it may invest. It seeks to identify UK companies, with attractive long-term business models offering the potential for good dividend growth and capital returns over the long term.

ESG investment framework
Analysing ESG issues is an important part of the analysis of a company’s business fundamentals. Environmental factors consider a company’s impact on the environment, social factors consider the way businesses treat and value people, and governance factors focus on corporate policies and how companies are governed. We believe companies with sound governance practices and strong stakeholder relations, that manage relevant environmental and social risks responsibly, have a greater propensity to create long-term value for shareholders. Key ESG issues considered as part of the investment process include corporate governance, human capital and diversity, climate change, controversies, disclosure, transparency, and business ethics.

Fixed Income

The fixed income sub-portfolio seeks to provide a return from a combination of income and capital growth over the long term. The team seek to invest in G71 government debt and global company bonds by incorporating ESG factors in investment decisions. This includes investment in labelled bonds, such as Green, Social and Sustainability Bonds, which are any type of bond instrument where the proceeds will be exclusively applied to eligible environmental and social projects or a combination of both 2.

ESG Integration within Fixed Income
Our approach to ESG integration seeks to maximise our analytical strengths. At its heart is a forward-looking approach as our primary consideration is to identify value and avoid unwanted risk. ESG factors can have a material impact on credit outcomes, which is why we believe they are an important consideration within our decision-making. We place importance on an issuer’s willingness to improve and seek to corroborate what companies say with evidence of action.

Three pillars to our approach
1. Proprietary Rating Framework
▪ Robust, integrated ESG framework which combines a top-down sector view, bottom-up data-driven company scoring and a forward-looking qualitative assessment

2. Engagement and Stewardship
▪ Proactive approach to engagement and stewardship, promoting positive company dialogue rather than relying on exclusions

3. Portfolio Monitoring and reporting
▪ Proprietary tool, ESG Explore, provides a 360 view of portfolio and benchmark to screen for ESG risks and opportunities over time, including forward-looking indicators.

Our ratings model is a four-step process. Each step is important as we combine third-party ESG data with our own research and analysis. The forward-looking assessment provides a qualitative overlay to the earlier quantitative metrics to arrive at a final ESG rating for a corporate issuer.

1. Sector assessment: top-down view of material ESG issues at sector level
2. Company baseline score: bottom-up, data-drive and leveraging third-party data
3. Forward-looking assessment: subjective analyst views from timely and dynamic ratings
4. JHI ESG rating: final proprietary sector-agnostic rating

Our proprietary ESG ratings are reflected in our data analytics tool Quantum, which is utilised by our investment teams as well as in ESGX. The ESG rating allows for sufficient differentiation to be meaningful when integrating financially-material ESG into our decision-making. For example, for a security with a high ESG risk (marked as Red), we expect a greater risk premium to be incorporated into the overall relative value assessment. Analysts leverage insights from ESG Explore and their engagements to refine the ESG ratings, which then influence the broader credit recommendations.

The overall credit recommendations are formulated by considering industry insights, fundamental analysis (e.g. balance sheet strategy, cash flow generation, management analysis), market dynamics, valuations, ESG and quantitative analysis to develop trade ideas. These trade ideas are then shared with the portfolio managers who determine the overall allocation of the portfolio.

By blending third-party data with our own research, quantitative metrics with qualitative overlays, and assessing issuers from both top-down and bottom-up directions, we gain a comprehensive understanding of the factors influencing corporate borrowers.

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’:

This Strategy is helping to shift the dial from brown to green by taking a responsible approach to investing in the shares and bonds of global companies by incorporating environmental, social and governance (ESG) factors in investment decisions and by avoiding companies that the investment manager considers to be involved in business activities and behaviours that may be environmentally and/ or socially harmful.

SDR Labelling:

Unlabelled - promotes sustainable characteristics (has CFD)

SDR Literature:

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