Sustainable, Responsible &/or ESG Policy:

The Global Sustainable Equities 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.

The team believe there is a strong link between sustainable development, innovation, and long-term compounding growth. Our investment framework leads us to invest in companies that we believe contribute to the development of a more sustainable global economy, through their revenue alignment with ten environmental and social themes. At the same time, it helps us stay on the right side of disruption by seeking to avoid companies we consider to be involved in activities that are harmful to the environment and society.

We believe this approach will provide clients with a persistent return source, deliver future compound growth, and help mitigate downside risk.

Key distinctions

30 years of sustainability thought leadership
We have a long and successful track record in the consistent application of our sustainability framework – the strategy was launched in 1991 and Hamish Chamberlayne 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.

Investing for sustainable outcomes
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 Global Sustainable Equity (GSE) portfolio management team works in collaboration with Janus Henderson Investors’ (the “firm” or “Janus Henderson”) global equity research platform and draws upon the deep knowledge and domain expertise of the sector and regional teams.

Explicitly low carbon
We consider six 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 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 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 environmental and social 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 Global Sustainable Equity Strategy_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.

• Thematic revenue alignment: Ten environmental and social 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 portfolio 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.

Source: Janus Henderson Investors as at 31 December 2025.

Thematic framework
Our thematic criteria lead us to invest in businesses that contribute to a more sustainable society and environment by virtue of the products or services they sell and by the way in which they manage their operations, thereby supporting the Sustainable Development Goals.

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 a company to be eligible for our portfolio at least 50% of its revenues will be aligned with at least one of these sustainable development themes.

Environmental and social investment themes

Source: Janus Henderson Investors, as at 31 December 2025.
Note: As of 15 April 2025, under the FCA SDR, Quality of Life holdings are not included in the 70% which contribute towards the Fund’s sustainability objective.

Investing for sustainable development is inherent in our approach and integral to all investment decisions. All investments must demonstrate thematic alignment 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 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.

We believe our exclusions make sense ethically, socially, environmentally, and financially. We seek to avoid investing in businesses that have products or operations directly associated with:

Source: Janus Henderson Investors, as at 31 December 2025.
Note: For a full list of avoidance criteria, please refer to the Global Sustainable Equity Strategy’s Investment Principles document at www.janushenderson.com.

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 third pillar of the investment approach is constructed around two key questions, ‘Is the world a better place because of this company?’ and ‘Is there a large growth opportunity?’. The team have a rigorous fundamental research process looking at both ESG and financial factors in an integrated fashion. The team ultimately analyses every company based on the ‘3 Ps’ of their ‘triple bottom line’ framework: how they generate Profits, how they impact People; and how they impact the Planet.

Source: Janus Henderson Investors, as at 31 December 2025.
Note: The triple bottom line (TBL) is a framework or theory that recommends that companies commit to focus on social and environmental concerns just as they do on profits.

The team seeks to identify businesses with long-term compounding characteristics, and with optionality upside, which are trading at discounts to their intrinsic value. Typically, the team looks 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 does 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 under-appreciates the long-term risks to others. We consider all 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

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

• 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 50 to 70 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 Quarterly ESG, Sustainability and Climate report. This details how the portfolio holdings are having an environmental or social outcome, demonstrating the portfolio thematic alignment as well as providing depth on our corporate engagement and proxy voting activity. We also review and map our portfolio to the UN SDGs and report the outcome of this analysis. This report also discloses details on portfolio ESG Scores and controversies as well as the portfolio environmental, social and governance KPIs in great detail. We also produce an Investment Principles document and update this periodically and this covers details on our investment philosophy, our definition of sustainability, and an in-depth description of our investment framework that leads us to invest in companies that contribute to the development of a more sustainable global economy, through their revenue alignment with ten environmental and social themes, along with avoidance criteria.

Please refer to the link Global Sustainable Equity Strategy_Investment Principles and Janus Henderson Global Sustainable Equity Fund_ESG Report Q4 2025 for further details.

Resources, Affiliations & Corporate Strategies:

As at 31 December 2025, Janus Henderson has 32 Responsibility Team resources. This centralised team are our ESG subject-matter experts who partner with our investment teams on ESG. On our investment teams, we have 10 dedicated ESG experts embedded within numerous investment teams. Additionally, we have 15 portfolio managers* on Janus Henderson’s Brighter Future (ESG-focused) Funds. Our portfolio managers are further supported by our central research functions and/or investment team analysts.

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

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

Our approach to Responsibility

Janus Henderson has a three-pronged approach to Responsibility.

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

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

• The third is our JHI Brighter Future Funds. For those clients who want to achieve their risk and return objectives using ESG criteria, we have and continue to build our suite of JHI Brighter Future Fund strategies that have an ESG focus, alongside the primary financial objective.

Responsible Investment Policy overview and Integration

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

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

Engagement and stewardship approach

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

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

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

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

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

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

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

We continue to remain a signatory to the Financial Reporting Council’s UK Stewardship Code, regarded as a benchmark in investment stewardship, as well as supporting Japan’s Stewardship Code, and broader initiatives around the world including the UN-supported Principles for Responsible Investment (PRI).

Our commitment to clients

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

Janus Henderson Investors Brighter Future Funds

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

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

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

Companies that provide ESG solutions or enable others
Invest in companies that offer products and services that are essential to addressing financially-material ESG issues.

Firm-wide exclusions policy

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

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

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

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

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

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

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

Implementation

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

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

Responsibility Team History

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

Responsibility Team
The central Responsibility Team is a specialised in-house group that brings together expertise in responsible investment and governance, ESG data and analytics, thematic research, engagement advisory, proxy voting, and regulatory strategy, partnering with and serving as a resource for our investment desks. They play a leading role in working with investment desks to enhance their ESG integration processes and externally leading our active participation in numerous responsibility initiatives. Fundamental, bottom-up research has been at the core of our investment process for more than 45 years and this partnership leads to enhanced research and decision-making by marrying the sector and industry expertise of the investment teams with the responsibility skills of the Responsibility Team.

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

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

Goals for Responsibility Team and Chief Responsibility Officer

Our Chief Responsibility Officer oversees the areas of our three-pronged approach to Responsibility.

• The first is our own corporate responsibility. Our commitment to responsibility extends to our corporate practices, embodying the principle that ‘Responsibility starts at home’. We need to ensure our own policies and practices reflect what our stakeholders demand. At a corporate level, behaving responsibly impacts our people, our culture, and our choices with the ultimate aim of investing in a brighter future for our clients. We leverage our influence to responsibly deliver value to our clients, employees, shareholders, and the wider community.
• The second is ESG integration. At an investment level, we integrate financially material ESG factors into our analysis and processes for most of our actively managed strategies, as appropriate, to help us identify opportunities and risks and to drive the long-term value of the companies in which we invest.
• The third is our JHI Brighter Future Funds. For those clients who want to achieve their risk and return objectives using ESG criteria, we have and continue to build our suite of JHI Brighter Future Fund strategies that have an ESG focus, alongside the primary financial objective. This can be evidenced by, for example, thematic selection criteria, commitments to beat a benchmark on specific ESG metrics, or targeting a positive environmental or social impact.

To accomplish this, the Responsibility Team and Chief Responsibility Officer have five goals, as agreed upon by the Janus Henderson Group Board of Directors:

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

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

• Our Responsibility Strategy and Operations pillar oversees firmwide responsibility delivery by providing the data, infrastructure, regulatory coordination, and operational support that underpin investment decision-making, client outcomes, and corporate sustainability. They support our investment and non-investment teams in areas of ESG data and analytics, regulations and risk (collaborating with Regulatory, Risk, Compliance, and Legal on relevant regulatory requirements / disclosures), corporate sustainability (development and support of our corporate environmental strategy and execution), and public affairs.
• Our Responsible Investment and Governance pillar provides direct support to our investment teams. The focus of this partnership is on equipping and supporting our analysts and portfolio managers to do what they do best: research industries and securities to select the most attractive candidates for inclusion in our portfolios. Our team will partner with the investment teams to deliver ESG training, support on developing frameworks to identify financially material ESG risks and considerations, planning and conducting engagements, supporting research on issues that can impact cash flows or valuation, and advising proxy voting.
• Our Responsibility Client Solutions pillar focuses on partnering with our product distribution teams, and investment teams to enhance existing portfolios and deliver new portfolios to clients across varying levels of responsibility needs, from robust integration to ESG-focused strategies. They also partner with investment desks to continuously evolve our integration capabilities, including developing and refining integration frameworks that inform research, stewardship, and portfolio construction. The team also contributes to the development of training, reports, client responses, external communications, and Responsibility thought leadership topics.

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

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

Responsible Investment Policy Oversight and Governance

Board of Directors

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

ESG Oversight Committee

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

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

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

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

Internal Audit

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

Risk management functions

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

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

Compliance

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

Front Office Controls

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

ESG Ratings and Recognition

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

Janus Henderson has been certified as a CarbonNeutral® company since 2007, and we continued to be certified as a CarbonNeutral® company throughout 2024, including for emissions across our corporate Scope 1, 2, and a subset of upstream Scope 3, including business travel, waste, and homeworking. To achieve this certification, Janus Henderson’s emissions inventory has been independently assessed, and we have provided financing to a range of emission reduction projects, supporting essential renewable energy, afforestation, and methane capture from landfill gas to offset our remaining emissions. These projects additionally deliver co-benefits for the environment and society in accordance with the United Nations Sustainable Development Goals (SDGs). Additionally, we have been an investor signatory of the Carbon Disclosure Project since 2000 and we are a registered supporter of the Task Force on Climate-related Financial Disclosures (TCFD). In 2024 we maintained high scores in our Principles for Responsible Investment (PRI) reporting covering the prior year through 30 June 2024. Due to changes in the reporting structure, we elected to disclose only the mandatory PRI signatory reporting through June 2025; therefore we will not receive an updated PRI score until approximately November 2026, covering 1 July 2025 – 30 June 2026.

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

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

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

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

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

ESG Affiliations, Memberships, Initiatives and Certifications

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

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

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

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

Thought Leadership

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

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

In terms of specific themes and topics, we produced broader papers and debates on a variety of ESG issues, including methane emissions from the oil & gas industry, deforestation, the role of metals in decarbonisation, renewable energy, and electric and autonomous vehicles. We also published articles outlining our approach to ESG and natural capital investing.

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

Dialshifter

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

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