BNY Mellon Real Return Fund (Responsible) Fund

SRI Style:

Sustainability Tilt

SDR Labelling:

Unlabelled with sustainable characteristics

Product:

OEIC

Fund Region:

Global

Fund Asset Type:

Multi Asset

Launch Date:

24/04/2018

Last Amended:

Sep 2025

Dialshifter ():

Fund/Portfolio Size:

£188.87m

(as at: 30/06/2025)

Total Assets Under Management:

£77829.52m

(as at: 30/06/2025)

ISIN:

GB00BD6DRR91, GB00BD6DRD55, GB00BD6DRF79, GB00BD6DRY68, GB00BD6DRZ75, GB00BD6DRW45, GB00BD6DRH93, GB00BD6DRP77

Objectives:

The Fund seeks to deliver positive returns on a rolling 3-year basis after fees. The Fund aims to deliver positive returns before fees within a range cash (SONIA (30-day compounded)) on a rolling 3-year basis and cash (SONIA (30-day compounded)) + 4% per annum on a rolling 5-year basis (meaning a period of three years or five years respectively, no matter which day you start on). However, positive returns are not guaranteed, and a capital loss may occur.

 

Sustainable, Responsible
&/or ESG Overview:

The Fund seeks to deliver positive returns on a rolling 3-year basis after fees by investing in a portfolio of UK and international securities across a broad range of asset classes. It also aims to deliver positive returns before fees within a range of cash (SONIA (30-day compounded)) on a rolling 3-year basis and cash (SONIA (30-day compounded)) + 4% per annum on a rolling 5-year basis. However, positive returns are not guaranteed and a capital loss may occur. While pursuing its investment objective, the Fund invests a minimum of 70% of its portfolio in securities with sustainability (i.e. positive environmental and/or social) characteristics.

Primary fund last amended:

Sep 2025

Information directly from fund manager.

Fund Filters

Sustainability - General
Sustainability policy

Funds that have policies that consider (environmental and social) sustainability issues. Strategies vary but are likely to consider environmental issues like climate change, carbon emissions, biodiversity loss, resource management, environmental impacts; and social issues like equal opportunities, human rights, labour standards, diversity and adherence to internationally recognised codes. See fund information.

Encourage more sustainable practices through stewardship

A core element of these funds aim to encourage higher sustainability standards across business practices through responsible ownership / stewardship / engagement / voting activity

UN Global Compact linked exclusion policy

Find funds that use the UN Global Compact to inform or help direct where they can or cannot invest and will typically not invest in companies with significant breaches (low standards) - although strategies vary. (The UNGC covers a wide range of issues - search 'UNGC'). See https://unglobalcompact.org/

Transition focus

The delivery of the shift to a sustainable future is a core feature of this fund and its investment strategy. See eg https://www.transitionpathwayinitiative.org/

Environmental - General
Limits exposure to carbon intensive industries

Funds that limit or 'reduce' their exposure to carbon intensive industries (ie sectors which are major contributors to climate change. Funds vary - some funds may be 'underweight' in this area which means they may have some investment in highly carbon intensive areas. Funds of this kind may choose companies they consider to be 'best in sector' and encourage ever higher standards. Strategies vary. See fund information for further details.

Climate Change & Energy
Fracking and tar sands excluded

Funds that avoid companies involved in fracking and tar sands - which are widely regarded as controversial methods of oil and gas extraction. Strategies vary. See fund information for further information.

Arctic drilling exclusion

Funds that avoid companies that are involved in extracting oil from the Arctic regions. See fund literature for further details.

Fossil fuel reserves exclusion

Funds that avoid investing in companies with coal, oil and gas reserves. See fund information for further details.

Clean / renewable energy theme or focus

Find funds where investment in clean / renewable energy companies an other assets is central to their investment selection strategy. The proportion of the fund that is directly or indirectly invested in renewable energy varies between funds and over time. See fund information for further details.

Encourage transition to low carbon through stewardship activity

A core element of these funds will aim to encourage the transition to lower carbon activities through responsible ownership / stewardship / engagement / voting activity

Social / Employment
Mining exclusion

All mining companies excluded

Ethical Values Led Exclusions
Tobacco and related product manufacturers excluded

Companies are excluded if they are involved in any aspect of the production chain for tobacco products, including cigarettes, vaping, e-cigarettes, chewing tobacco and cigars.

Controversial weapons exclusion

Find funds that exclude companies which make controversial weapons such as landmines, cluster munitions and chemical weapons. See fund literature for further information.

Armaments manufacturers avoided

Find funds that avoid companies that manufacture products intended specifically for military use. Fund strategies vary - particularly with regard to non-strategic military products. See fund literature for fund specific details.

Military involvement not excluded

Find funds that do not exclude companies with military contracts - this may include medical supplies, food, safety equioment, housing, etc. See fund literature for further information.

Alcohol production excluded

Find funds that avoid investment in companies involved in the production of alcohol. Strategies vary; some funds allow a small proportion of profits to come from this area. See fund literature for further information.

Gambling avoidance policy

Find funds that avoid companies with significant involvement in the gambling industry. Some funds may allow a small proportion of profits to come from this area. See fund policy for further details.

Pornography avoidance policy

Find funds that avoid companies that derive significant income from pornography and related areas. Strategies vary. See fund details for further information.

Gilts & Sovereigns
Invests in gilts / government bonds

Find funds that invest in loans issued the government, commonly known as gilts or government bonds. These may or may not be ringfenced for specific projects (see additional options). See fund literature for any selection criteria.

Gilts / government bonds - exclude some

Find funds that avoid investing in 'some' gilts or government bonds. Strategies vary, but this may relate to avoiding specific countries or particular reasons for bond issuance. 'Green gilts' for example would be likely to be acceptable. See fund literature for further information.

Invests in sovereigns subject to screening criteria

Find funds that invest in financial instruments issued by governments, but will only hold those that meet certain environmental and or social criteria. This may, for example mean certain assets are excluded in line with eg Freedom House research. Strategies vary, see fund literature for more information.

Banking & Financials
Invests in banks

Find funds that include banks as part of their holdings / portfolio.

Invests in financial instruments issued by banks

Finds funds that include financial instruments (cash, derivatives and / or foreign exchange) issued by banks. See fund literature for further information as strategies vary.

Invests in insurers

Funds that do or may invest in insurance companies.

Governance & Management
Avoids companies with poor governance

Find funds that aim to avoid investing in companies with poor governance practices.(e.g. board structure, management practices etc.) Views may however vary on what counts as 'poor' practices - and funds may not immediately divest as they may prefer to work to encourage higher standards. See fund literature for further information.

UN sanctions exclusion

Exclude companies that are subject to United Nations sanctions. See eg https://main.un.org/securitycouncil/en/content/un-sc-consolidated-list

Encourage higher ESG standards through stewardship activity

A core element of these funds will aim to encourage higher ESG standards through responsible ownership / stewardship / engagement /voting activity

Asset Size
Invests in small, mid and large cap companies / assets

Find a fund that invests in a combination of small, medium and larger (potentially multinational)companies.

How The Fund Works
Negative selection bias

Find funds where their main 'ethical approach' is to avoid companies by using negative screening criteria. Read fund literature for further information.

Data led strategy

Find funds that make stock selection (and ongoing fund management) decisions based on ESG data or company ratings (normally supplied by third parties) rather than focusing on what individual companies do, how they operate or their plans for the future

Combines norms based exclusions with other SRI criteria

Find funds that make significant use of internationally agreed 'norms' (e.g. United Nations Global Compact - UNGC - or the UN Sustainable Development Goals - SDGs) as part of their investment selection process alongside additional SRI criteria such as positive or negative stock selection policies and/or stewardship strategies.

Balances company 'pros and cons' / best in sector

Find funds that consider both the 'positive' and 'negative' aspects of company behaviour and make balanced, considered decisions as part of their investment approach. May apply to a range of different issues and policy areas.

Norms focus

Find funds that use internationally agreed standards, conventions and 'norms' to help direct where the fund can and cannot invest (e.g. the UN Global Compact, UN Sustainable Development Goals). Read fund literature for further information.

SRI / ESG / Ethical policies explained on website

Find funds that have published explanations of their ethical, social and/or environmental policies online (i.e. fund decision making strategies/ buy/sell &/or asset management strategies).

Fund uses unscreened ‘diversifiers’ to help manage risk

Fund invests in assets that have not passed its usual sustainability criteria or screening standards in order to help manage investment risk. This may be limited or significant. See literature.

Do not use stock / securities lending

This fund does not use stock lending for performance or risk purposes.

Unscreened Assets & Cash
Assets typically aligned to sustainability objectives 70 - 79%

The percentage of assets held within the fund that match the fund’s sustainability objectives and are not being held purely for risk management purposes, such as derivatives and cash equivalent assets.

Intended Clients & Product Options
Available via an ISA (OEIC only)

Find funds that are available via a tax efficient ISA product wrapper.

Fund Management Company Information

About The Business
Boutique / specialist fund management company

Find fund management companies that are smaller or specialise in particular areas - notably, ideally ESG related. Strategies vary.

Responsible ownership / stewardship policy or strategy (AFM company wide)

Finds fund management companies that have a published company wide stewardship, engagement and / or responsible ownership policy or strategy that covers all investments. Stewardship typically involves encouraging higher ESG standards through voting and dialogue.

ESG / SRI engagement (AFM company wide)

Find fund management companies that actively encourage higher 'environmental, social and governance' and/or 'sustainable and responsible investment' practices across investee companies - typically where the aim is to encourage positive change that is aligned with the best interests of investors. Strategies vary. See additional information and options.

Vote all* shares at AGMs / EGMs (AFM company wide)

Find fund managers that vote all* the shares they own at Annual General Meetings and Extraordinary General Meetings. A commitment to voting shares is a key indicator of 'responsible share ownership' demonstrating their support for or disagreement with management policy. (*situations can legitimately, occasionally occur where voting proves impossible, but in principle all shares should be voted.)

Responsible ownership policy for non SRI funds (AFM company wide)

Find funds run by fund managers that apply Responsible ownership or 'Stewardship' policies to all or most of their investment assets. This means active involvement (e.g. voting, dialogue) with the companies they invest in across funds (not normally limited to ethical or SRI options.) Read fund literature for further information.

Integrates ESG factors into all / most (AFM) fund research

Find fund management companies that consider environmental, social and governance (ESG) issues when deciding whether or not to invest in a company for all / almost all of their funds and other assets. This is increasingly seen as part of sound risk management.

In-house diversity improvement programme (AFM company wide)

Finds organisations / fund managers that have an in-house (company wide) diversity improvement programme - meaning that they are working to ensure that within their own businesses they employ people from diverse backgrounds - often typically focused on ethnicity and/or sex.

Vulnerable client policy on website (AFM company wide)

Asset manager has information on their website that explains how they treat 'vulnerable clients' (as set out in FCA regulation)

Collaborations & Affiliations
PRI signatory

Find fund management companies that have signed up to the UN backed 'Principles of Responsible Investment'.

UKSIF member

Find fund management companies that are members of UKSIF - the UK Sustainable Investment and Finance association

Fund EcoMarket partner

Find fund management companies that have partnered with Fund EcoMarket - meaning that they are helping to improve access to information on sustainable and responsible investment by paying an annual fee to us which enables us to publish information for free. Partner funds are listed ahead of other funds and have their logos displayed.

Investment Association (IA) member

Fund management entity is a member of the Investment Association https://www.theia.org/

Resources
In-house responsible ownership / voting expertise

Find fund management companies that employ people to steer and support fund managers in voting shares at company AGM's and EGMs in ways that are consistent with encouraging higher ESG/sustainability standards.

Employ specialist ESG / SRI / sustainability researchers

Find a fund management company that directly employs specialist ESG/SRI/sustainability researchers or analysts. This allows asset managers to discuss environmental, social and governance risks and opportunities directly with companies.

Use specialist ESG / SRI / sustainability research companies

Find fund management companies that makes use of expert external research companies. This can help deliver specialist expertise and means resources are pooled with other investors.

Accreditations
UK Stewardship Code signatory (AFM company wide)

Find fund managers that are signatories to the FRC UK Stewardship Code, which sets out a framework for constructive investor / investee relations where fund managers are encouraged to behave like responsible, typically longer term 'company owners'.

Engagement Approach
Regularly lead collaborative ESG initiatives (AFM company wide)

Find fund management companies that regularly initiate or run industry wide (collaborative) investor projects aimed at raising environmental, social and governance standards amongst investee companies.

Engaging on climate change issues

Fund manager has stewardship /responsible ownership strategy that is focused on addressing climate change with investee assets.

Engaging with fossil fuel companies on climate change

Asset manager has a stewardship /responsible ownership strategy that involves working with fossil fuel companies on climate change related issues. See fund manager website for details.

Engaging on biodiversity / nature issues

The asset manager has a responsible ownership / stewardship strategy that focuses on biodiversity and nature issues relating to the assets they invest the aim of which will be to reduce harm and or deliver improvement. Strategies vary. https://tnfd.global

Engaging to encourage a Just Transition

Asset manager has a responsible ownership / stewardship strategy which means they are working to encourage the shift to more sustainable business practices in ways that respect and are sensitive to social issues and the impact change has on people effected by the changes that are taking place. https://www.transitionpathwayinitiative.org/ https://transitiontaskforce.net/

Engaging on human rights issues

Asset manager has responsible ownership / stewardship strategy in place which aims to address human rights issues in investee companies (and potentially their suppliers) with the aim of raising standards

Engaging on labour / employment issues

Asset manager has responsible ownership / stewardship strategy in place that aims to improve labour standards for the benefit of employees in investee companies (and potentially their suppliers)

Engaging on diversity, equality and / or inclusion issues

Asset management company has a stewardship strategy in place which involves working to raise diversity, equality and inclusion standards across investee assets

Engaging to stop modern slavery

working with the assets they hold to help stamp out modern slavery - where direct or indirect company employees are exploited for business benefits.

Engaging on governance issues

Fund managers have stewardship strategies in place that focus on improving governance standards across investee assets

Engaging on responsible supply chain issues

Has a stewardship / responsible ownership strategy that encourages responsible supply chain - ie the managers will discuss environmental, social and governance issues with investee companies with the aim of raising standards

Stewardship escalation policy

Escalation policies describe how a manager will proceed if stewardship / engagement activity is not successful in the short term.

Climate & Net Zero Transition
Net Zero commitment (AFM company wide)

Fund management organisations that have pledged to reduce their greenhouse gas emissions to ‘net zero’. Strategies vary - this area is changing rapidly.

Net Zero - have set a Net Zero target date (AFM company wide)

This asset management company has set a date by which they plan to achieve net zero greenhouse gas / CO2e emissions.

Encourage carbon / greenhouse gas reduction (AFM company wide)

Find fund management companies that are working with the companies they invest in to encourage reductions in carbon dioxide and other greenhouse gas emissions.

Carbon transition plan published (AFM company wide)

Finds organisations / fund managers that have a company wide carbon transition plan - meaning that they have plotted a path to how they will move away from activities that produce or use carbon based energy sources (that emit greenhouse gases) towards clean, alternative, renewable energy sources.

Working towards a ‘Net Zero’ commitment (AFM company wide)

Finds organisations / fund management companies that are in the process of working out how to make a ‘net zero commitment’ - meaning that when that is finalised they will have started the process of reducing their total greenhouse gas emissions to'zero'.

Committed to SBTi / Science Based Targets Initiative

See https://sciencebasedtargets.org/

Transparency
Publish responsible ownership / stewardship report (AFM company wide)

Find fund management companies that publish a report detailing their responsible investment ownership - also known as 'Stewardship' - activity.

Full SRI / responsible ownership policy information on company website

Find companies that publish information about their sustainable and responsible investment strategies on their company website.

Full SRI / responsible ownership policy information available on request

Find fund management companies that will supply information about their sustainable and responsible investment activity on request.

Publish full voting record (AFM company wide)

Fund management companies that publish a full record of how they vote their shares at AGMs (annual general meetings) and EGMs (extraordinary general meetings). Voting strategies have an important role to play encouraging higher environmental, social and governance standards.

Net Zero transition plan publicly available (AFM company wide)

This asset management company has published a plan that explains how they are going to achieve net zero greenhouse gas / CO2e emissions.

Comments

Please Note:

  • Controversial weapons avoidance policy (AFM company wide) - Our policy is to exclude manufacturers of the following weapons: anti-personnel mines, cluster munitions, chemical weapons, biological weapons, nuclear weapons, Incendiary weapon, non-detectable fragment, blinding laser weapons, white phosphorus weapons, depleted uranium weapons.

Sustainable, Responsible &/or ESG Policy:

Sustainable investment philosophy

We consider sustainable investment to be about investing with a clear intent to deliver environmental and/or social outcomes alongside generating a financial return. The strategies that follow the Newton sustainable investment framework seek to balance financial, social and environmental outcomes to support long-term shareholder returns.

Sustainable investment framework

This framework is focused on two main components: defining what is incompatible with a sustainable universe --‘sustainable investment restrictions’ and defining what constitutes a sustainable investment. The latter rests on an approach that focuses on key sustainable investment themes with underlying sustainable activities and how an investment is connected with this – through alignment or contribution measures.

Sustainable investment universe

The portfolio manager is responsible for applying the Newton sustainable investment framework and ensuring that the security is eligible following a review which is documented. The review determines whether the investment contributes towards one or more of the Newton sustainable investment themes (sustainable contributors) or demonstrates strong environmental and/or social practices that align with one or more of the Newton sustainable investment themes (sustainable aligners).

Sustainable contributors: These are companies that provide solutions (products and services) that address the most pressing environmental or social challenges. Our sustainable investment framework is applied through a series of measures, such as revenues from products relating to Renewable and low-carbon energy sources, resource efficiency, affordable housing, medical technology and healthy eating. As a measure of their contribution, each sustainable contributor must have at least 30% revenue exposure (in aggregate) from one of more of the sustainable activities, as defined in the sustainable investment framework, or have at least 30% capital expenditure (CAPEX) or operational expenditure (OPEX) aligned to the EU Taxonomy.

Sustainable aligners: These are companies that manage to a high standard the social and environmental issues relating from their direct operations and supply chains as well as integrate sustainability priorities into their business strategy. This is primarily about the internal management of a company’s operations and supply chain where we seek to invest in leaders or best-in-class industry players. Companies that integrate sustainability into their business strategy have committed explicitly to improving their environmental and social impacts by reducing negative externalities that is expected to lead to a transformation of their business models. The outcome of this mitigation and transformation of the negative externality results in a meaningful positive outcome for society and/or the environment.

These two classifications are guided by frameworks, developed, and maintained by the Newton RI team, ensuring robustness and consistency in order to identify the suitable sustainable investment propositions. The overall framework is reviewed regularly and may evolve over time with Newton’s own thinking as well as with regulatory development.

Sustainable investment restrictions*

The sustainable investment restrictions mainly seek to avoid investments in areas of significant social or environmental harm. These restrictions cannot be overridden.

Here we seek to avoid investments involved in areas of high negative externalities, those that cause significant long-term societal harm, investments that have been identified as having severe controversies and/or violating one or more of the ten UN Global Compact Principles covering areas including human rights, labour practices, corruption and the environment. We do not believe that exposure to such activities is aligned with our sustainable investment framework.

To identify these companies, we use a combination of external service providers including Bloomberg, ISS, RepRisk, CDP and Factset to inform our decisions. The sustainable investment restrictions are hard coded into the Newton trade process and any potential violations are caught in the pre-trade compliance checks. Revenue threshold parameters applied through these restrictions reflect just one part of our sustainable investment framework – a key part of this process is the additional research and analysis conducted by the investment team.

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Note: 1 Some strategies following the Newton Sustainable Investment process may choose to add to these exclusions – but may never subtract.
Source: Newton, 30 January 2025.

However, please note: revenue threshold parameters reflect just one part of our sustainable investment process – a key part of this process is the additional research and analysis conducted by the investment team.

Our process seeks to clearly distinguish between activities that are subject to hard exclusions versus those activities that sustainability portfolio managers may be able to invest in in certain circumstances (precautionary pool).

Precautionary pool

For areas that have been identified as having controversies or the potential to cause harm (such as fossil fuels other than thermal coal, animal welfare, conventional defence and nuclear power) but are not covered by the sustainable investment restrictions, portfolio managers are alerted, when considering such investments, to review the controversial activity through what is referred to as the 'precautionary pool'. The precautionary pool includes companies that have been flagged in relation to their involvement in heavy-emitting industries, hold exposures to activities that are restricted, but at lower revenue thresholds, and areas such as nuclear power and animal welfare, where there may be nuances in the investment case that are deemed important to be highlighted.

The full list of activities caught currently under the precautionary pool is included below:

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Note: 1 The RI team maintains a list of companies that are tagged under the ‘precautionary pool’. Portfolio managers are alerted to this pool in the sustainable investment documentation portal (the Newton ‘RI App’). The portfolio managers are encouraged to work with the RI adviser assigned to the portfolio, to ensure that the managers are comfortable that the investment is not in conflict with the objectives of their strategy.
Source: Newton, 30 January 2025.

Bonds

Market participants and credit rating agencies have been placing increasing importance on non-financial factors in determining credit ratings, and understanding default risk on the debt issued by sovereigns. We believe a country’s competitiveness is dependent on the availability and quality of economic, natural, human and institutional capital. Countries that allocate and act as stewards of these capital resources effectively are likely to experience stable long-term growth and show more economic resilience. We evaluate factors such as natural resource depletion, social cohesion and advancement, conflict and institutional strength in order to understand if the returns on offer from sovereign debt are justified given the risks attached.

Since we believe that the durability of a sovereign bond relates to a number of factors we seek to gain a holistic view of a country, taking into account the various positive and negative factors. We consider data from a range of sources including the World Bank, Transparency International, IMF, Yale University, Notre Dame Institute and others.

We do not apply thresholds when assessing each individual data source, but instead use relative thresholds at the aggregated data level. There are two parts to the calculation – one is the overall score and the other is the momentum. While the score is on a relative basis, momentum is fundamental in nature. All of the indicators are classified into the four capitals mentioned above and then are combined to calculate results at the country level. The country level score and momentum for all countries are categorized into three parts (For Score – Strong, Average and Weak, For Momentum – Positive, Stable and Negative) which then allows for these countries to be allocated into a 3x3 matrix. Each quarter, the model is reviewed by the fixed income and RI specialists to assess whether current affairs have changed our outlook described within the matrix.

Those countries rated ‘weak’ and which do not have positive momentum cannot be included in our sustainable investment strategies. Those countries rated ‘average’ (irrespective of momentum) and ‘weak’ with positive momentum can only be included in the sustainable strategies subject to further work being completed by the sovereign specialist and subsequently agreed by the RI team.

Resources, Affiliations & Corporate Strategies:

Newton has a centralised responsible investment team. This team is the centre of excellence for all matters related to responsible investment, and with its deep functional knowledge of the responsible investment space and how it is evolving, it provides guidance, support and subject-matter expertise to our wider investment team. The responsible investment team, as you can see below, is global in its footprint and diverse in its employee base. The team is organised into three pillars of expertise – stewardship, research and analytics: these specialisations under the responsible investment umbrella allow us to bring further depth and expertise to each of these activities. The team’s compact size enables it to work cohesively and operate as one team.

Stewardship: Oversees the firm’s engagement framework and advocacy initiatives, focusing its efforts on meaningful outcomes for clients, and also undertakes the firm’s proxy voting activities. Provides subject-matter expertise to the investment team on governance risks and evolving expectations.

Sustainability research: Subject-matter experts consulting the investment and research teams, driving deep insights on sustainability-related subjects. The team manages Newton’s sustainability standards, definitions and frameworks.

Responsible investment analytics: Has strong quantitative and RI data expertise and owns the data ecosystem, creating and managing responsible investment data models, frameworks and tools that support ESG integration and sustainable investing. The team has built an innovative suite of building blocks that can be leveraged to develop scalable solutions to meet specific client requirements.

The role of the responsible investment team is to be a support function to the investment teams, to set standards around sustainable investment, and to coordinate and ensure effectiveness around our stewardship efforts. It guides the business around policies and direction of travel for sustainability and stewardship more broadly. The responsible investment team also owns and manages the overall governance systems to ensure we deliver against key codes and commitments including stewardship codes, industry principles such as the UN Principles for Responsible Investment, and industry pledges such as the Net Zero Asset Managers Initiative (NZAMi).

Supporting the team, and the wider business, are various external organisations and vendors including ESG service providers, memberships, and internal systems for monitoring and reporting.

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Affiliations
As investors and an intermediary in the financial system we play an important role in providing investors with access to investment solutions, and that with this comes an inherent responsibility to do what is right on behalf of our clients, as well as wider asset owners and stakeholders in the financial system. Our advocacy focus involves supporting or seeking to influence various issues and areas for the long-term interest of our clients and Newton.

Organisations and initiatives related to responsible investment matters in which Newton plays a formal role:

*Newton Japan was established as a legal entity in March 2023. Its prior commitment to the Japan Stewardship Code was under its previous structure.

ESG Governance

Having an effective management and governance framework is an important part of our overall business strategy. As investors, we understand the value of effective leadership and accountability. This is closely linked to the culture of our business, as leadership and accountability have equal importance in Newton’s governance. We have therefore established appropriate governance systems and controls to support our stewardship and RI policy. This policy is reviewed and approved by the Newton Sustainability Committee (NIM and NIMNA), which reports to the Newton Executive Management Committee (NEMC) (to note, the NEMC reports into NIM and NIMNA boards). The policy is also reviewed and approved by the NIMJ Investment Oversight Committee, which reports into the NIMJ Executive Management Committee. The NEMC has overall responsibility for defining Newton’s approach, values and actions across all Newton entities.

Two of our operating committees play important roles in relation to our stewardship and RI efforts:

  • Newton Sustainability Committee – oversees all aspects relating to stewardship and RI at NIM and NIMNA, including our investments, direct impacts and engagement with communities, and engagement with the wider market (advocacy) regarding RI and stewardship matters.
  • Newton Risk and Compliance Committee – supported by the Newton Conflicts of Interest Committee and the Emerging Risks Working Group.

These committees deal with various stewardship and RI aspects on an ad-hoc basis, including any relevant internal audit findings and actions as well as climate-related risk updates from internal groups.

Our Board Risk Committee also plays a role in the governance of our RI and stewardship efforts; it acts as an escalation point for any material issues identified through our governance systems and controls. For example, it has previously considered materials related to climate risk. We have also established the Newton Sustainable Investment Forum (SIF) as an oversight group to monitor our strategies with sustainability characteristics.

The role of the SIF is to:

  • Foster debate by bringing together a wider set of Newton investment team members focusing on sustainability, including sustainability portfolio managers and RI team members
  • Provide support by educating, training and sharing knowledge and insights among the investment team.

SDR Labelling:

Unlabelled with sustainable characteristics

Disclaimer

IMPORTANT INFORMATION
Past performance is not a guide to future performance.
The value of investments can fall. Investors may not get back the amount invested.
Income from investments may vary and is not guaranteed.
For Professional Clients only.
Provided solely for use by Fund Ecomarket.
BNY, BNY Mellon and Bank of New York Mellon are the corporate brands of The Bank of New York Mellon Corporation and may be used to reference the corporation as a whole and/or its various subsidiaries generally.
Issued in the United Kingdom by BNY Mellon Investment Management EMEA Limited, BNY Mellon Centre, 160 Queen Victoria Street, London EC4V 4LA. Registered in England No. 1118580. Authorised and regulated by the Financial Conduct Authority.
Newton global assets under management (AUM) is the combined total assets under management of Newton Investment Management Limited (‘NIM’), Newton Investment Management North America LLC (‘NIMNA’) and Newton Investment Management Japan Limited (‘NIMJ’).
Returns may increase or decrease as a result of currency fluctuations.
Costs incurred when purchasing, holding, converting or selling any investment, will impact returns.
Costs may increase or decrease as a result of currency and exchange rate fluctuations.

Newton manages a variety of investment strategies. How ESG analysis is integrated into Newton’s strategies depends on the asset classes and/or the particular strategy involved. ESG can be one of many inputs into the fundamental analysis. Newton will make investment decisions that are not based solely on ESG analysis. Other attributes of an investment may outweigh ESG analysis when making investment decisions.

*Newton’ and/or ‘Newton Investment Management’ is a corporate brand which refers to the following group of affiliated companies: Newton Investment Management Limited (“NIM”), Newton Investment Management North America LLC (“NIMNA”) and Newton Investment Management Japan Limited ("NIMJ").

Newton’s assets under management include assets collectively managed by NIM, NIMNA and NIMJ. In addition, AUM for Newton includes assets of bank-maintained collective investment funds for which Newton has been appointed sub-advisor, where Newton personnel act as dual officers of affiliated companies and assets of wrap fee account(s) for which Newton provides sub-advisory services to the primary manager of the wrap program.

For a full list of risks applicable to this fund, please refer to the Prospectus or other offering documents.
Please refer to the prospectus, and the KIID/KID before making any investment decisions. Go to www.bnymellonim.com
The Funds are sub-funds of BNY Mellon Investment Funds, an open-ended investment company with variable capital (ICVC) with limited liability between sub-funds. Incorporated in England and Wales: registered number IC27. The Authorised Corporate Director (ACD) is BNY Mellon Fund Managers Limited (BNY MFM), incorporated in England and Wales: No. 1998251. Registered address: BNY Mellon Centre, 160 Queen Victoria Street, London EC4V 4LA. Authorised and regulated by the Financial Conduct Authority.
Fund performance calculated as total return, including reinvested income net of UK tax and charges, based on net asset value. All figures are in GBP terms. The impact of an initial charge (currently not applied) can be material on the performance of your investment. Further information is available upon request.
Returns may increase or decrease as a result of currency fluctuations.
Costs incurred when purchasing, holding, converting or selling any investment, will impact returns.
Costs may increase or decrease as a result of currency and exchange rate fluctuations.

Benchmark: The Fund will measure its performance before fees against SONIA (30-day compounded) on a rolling annualised 3 year basis (the "3 year Benchmark") and SONIA (30-day compounded) +4% per annum on a rolling annualised 5 year basis (the "5 year Benchmark"). SONIA is a nearly risk-free rate meaning no bank credit risk is included, the rate can rise or fall as a result of central bank policy decisions or changing economic conditions. The Fund will use the 3 year Benchmark as a lower threshold for the Fund's performance to match or exceed over a rolling 3 year period, as it is representative of cash; and the 5 year Benchmark as an upper threshold for its performance to match or exceed over a rolling annualised 5 year basis, as it is consistent with the level of risk that the Fund takes. The Fund is actively managed, which means the Investment Manager has discretion over the selection of investments, subject to the investment objective and policies as disclosed in the Prospectus.
Newton manages a variety of investment strategies. How ESG analysis is integrated into Newton’s strategies depends on the asset classes and/or the particular strategy involved. ESG can be one of many inputs into the fundamental analysis. Newton will make investment decisions that are not based solely on ESG analysis. Other attributes of an investment may outweigh ESG analysis when making investment decisions.

KEY INVESTMENT RISKS
Objective/Performance Risk: There is no guarantee that the Fund will achieve its objectives. Currency Risk: This Fund invests in international markets which means it is exposed to changes in currency rates which could affect the value of the Fund. Derivatives Risk: Derivatives are highly sensitive to changes in the value of the asset from which their value is derived. A small movement in the value of the underlying asset can cause a large movement in the value of the derivative. This can increase the sizes of losses and gains, causing the value of your investment to fluctuate. When using derivatives, the Fund can lose significantly more than the amount it has invested in derivatives. Counterparty Risk: The insolvency of any institutions providing services such as custody of assets or acting as a counterparty to derivatives or other contractual arrangements, may expose the Fund to financial loss. Charges to Capital: The Fund takes its charges from the capital of the Fund. Investors should be aware that this has the effect of lowering the capital value of your investment and limiting the potential for future capital growth. On redemption, you may not receive back the full amount you initially invested. Responsible Investing Risk: The investment policy for this Fund places restrictions on its exposure to certain sectors or types of investments to reflect its responsible investing approach. The Fund's performance may be negatively impacted due to these restrictions in comparison to funds which do not have these restrictions. The Fund will not engage in securities lending activities and, therefore, may forego any additional returns that may be produced through such activities. Performance Aim Risk: The performance aim is not a guarantee, may not be achieved and a capital loss may occur. Funds which have a higher performance aim generally take more risk to achieve this and so have a greater potential for returns to vary significantly. Changes in Interest Rates & Inflation Risk: Investments in bonds/ money market securities are affected by interest rates and inflation trends which may negatively affect the value of the Fund. Credit Ratings and Unrated Securities Risk: Bonds with a low credit rating or unrated bonds have a greater risk of default. These investments may negatively affect the value of the Fund. Credit Risk: The issuer of a security held by the Fund may not pay income or repay capital to the Fund when due. Emerging Markets Risk: Emerging Markets have additional risks due to less-developed market practices. Shanghai-Hong Kong Stock Connect and/or the Shenzhen-Hong Kong Stock Connect ("Stock Connect") risk: The Fund may invest in China A shares through Stock Connect programmes. These may be subject to regulatory changes and quota limitations. An operational constraint such as a suspension in trading could negatively affect the Fund's ability to achieve its investment objective. China Interbank Bond Market and Bond Connect risk: The Fund may invest in China interbank bond market through connection between the related Mainland and Hong Kong financial infrastructure institutions. These may be subject to regulatory changes, settlement risk and quota limitations. An operational constraint such as a suspension in trading could negatively affect the Fund's ability to achieve its investment objective. CoCo's Risk: Contingent Convertible Securities (CoCo's) convert from debt to equity when the issuer's capital drops below a pre-defined level. This may result in the security converting into equities at a discounted share price, the value of the security being written down, temporarily or permanently, and/or coupon payments ceasing or being deferred. Investment in Infrastructure Companies Risk: The value of investments in Infrastructure Companies may be negatively impacted by changes in the regulatory, economic or political environment in which they operate. A complete description of risk factors is set out in the Prospectus in the section entitled "Risk Factors"

Fund Name SRI Style SDR Labelling Product Region Asset Type Launch Date Last Amended

BNY Mellon Real Return Fund (Responsible) Fund

Sustainability Tilt Unlabelled with sustainable characteristics OEIC Global Multi Asset 24/04/2018 Sep 2025

Objectives

The Fund seeks to deliver positive returns on a rolling 3-year basis after fees. The Fund aims to deliver positive returns before fees within a range cash (SONIA (30-day compounded)) on a rolling 3-year basis and cash (SONIA (30-day compounded)) + 4% per annum on a rolling 5-year basis (meaning a period of three years or five years respectively, no matter which day you start on). However, positive returns are not guaranteed, and a capital loss may occur.

 

Fund/Portfolio Size: £188.87m

(as at: 30/06/2025)

Total Assets Under Management: £77829.52m

(as at: 30/06/2025)

ISIN: GB00BD6DRR91, GB00BD6DRD55, GB00BD6DRF79, GB00BD6DRY68, GB00BD6DRZ75, GB00BD6DRW45, GB00BD6DRH93, GB00BD6DRP77

Contact Us: salessupport@bnymellon.com

Sustainable, Responsible &/or ESG Overview

The Fund seeks to deliver positive returns on a rolling 3-year basis after fees by investing in a portfolio of UK and international securities across a broad range of asset classes. It also aims to deliver positive returns before fees within a range of cash (SONIA (30-day compounded)) on a rolling 3-year basis and cash (SONIA (30-day compounded)) + 4% per annum on a rolling 5-year basis. However, positive returns are not guaranteed and a capital loss may occur. While pursuing its investment objective, the Fund invests a minimum of 70% of its portfolio in securities with sustainability (i.e. positive environmental and/or social) characteristics.

Primary fund last amended: Sep 2025

Information received directly from Fund Manager

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Fund Filters

Sustainability - General
Sustainability policy

Funds that have policies that consider (environmental and social) sustainability issues. Strategies vary but are likely to consider environmental issues like climate change, carbon emissions, biodiversity loss, resource management, environmental impacts; and social issues like equal opportunities, human rights, labour standards, diversity and adherence to internationally recognised codes. See fund information.

Encourage more sustainable practices through stewardship

A core element of these funds aim to encourage higher sustainability standards across business practices through responsible ownership / stewardship / engagement / voting activity

UN Global Compact linked exclusion policy

Find funds that use the UN Global Compact to inform or help direct where they can or cannot invest and will typically not invest in companies with significant breaches (low standards) - although strategies vary. (The UNGC covers a wide range of issues - search 'UNGC'). See https://unglobalcompact.org/

Transition focus

The delivery of the shift to a sustainable future is a core feature of this fund and its investment strategy. See eg https://www.transitionpathwayinitiative.org/

Environmental - General
Limits exposure to carbon intensive industries

Funds that limit or 'reduce' their exposure to carbon intensive industries (ie sectors which are major contributors to climate change. Funds vary - some funds may be 'underweight' in this area which means they may have some investment in highly carbon intensive areas. Funds of this kind may choose companies they consider to be 'best in sector' and encourage ever higher standards. Strategies vary. See fund information for further details.

Climate Change & Energy
Fracking and tar sands excluded

Funds that avoid companies involved in fracking and tar sands - which are widely regarded as controversial methods of oil and gas extraction. Strategies vary. See fund information for further information.

Arctic drilling exclusion

Funds that avoid companies that are involved in extracting oil from the Arctic regions. See fund literature for further details.

Fossil fuel reserves exclusion

Funds that avoid investing in companies with coal, oil and gas reserves. See fund information for further details.

Clean / renewable energy theme or focus

Find funds where investment in clean / renewable energy companies an other assets is central to their investment selection strategy. The proportion of the fund that is directly or indirectly invested in renewable energy varies between funds and over time. See fund information for further details.

Encourage transition to low carbon through stewardship activity

A core element of these funds will aim to encourage the transition to lower carbon activities through responsible ownership / stewardship / engagement / voting activity

Social / Employment
Mining exclusion

All mining companies excluded

Ethical Values Led Exclusions
Tobacco and related product manufacturers excluded

Companies are excluded if they are involved in any aspect of the production chain for tobacco products, including cigarettes, vaping, e-cigarettes, chewing tobacco and cigars.

Controversial weapons exclusion

Find funds that exclude companies which make controversial weapons such as landmines, cluster munitions and chemical weapons. See fund literature for further information.

Armaments manufacturers avoided

Find funds that avoid companies that manufacture products intended specifically for military use. Fund strategies vary - particularly with regard to non-strategic military products. See fund literature for fund specific details.

Military involvement not excluded

Find funds that do not exclude companies with military contracts - this may include medical supplies, food, safety equioment, housing, etc. See fund literature for further information.

Alcohol production excluded

Find funds that avoid investment in companies involved in the production of alcohol. Strategies vary; some funds allow a small proportion of profits to come from this area. See fund literature for further information.

Gambling avoidance policy

Find funds that avoid companies with significant involvement in the gambling industry. Some funds may allow a small proportion of profits to come from this area. See fund policy for further details.

Pornography avoidance policy

Find funds that avoid companies that derive significant income from pornography and related areas. Strategies vary. See fund details for further information.

Gilts & Sovereigns
Invests in gilts / government bonds

Find funds that invest in loans issued the government, commonly known as gilts or government bonds. These may or may not be ringfenced for specific projects (see additional options). See fund literature for any selection criteria.

Gilts / government bonds - exclude some

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Invests in sovereigns subject to screening criteria

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Banking & Financials
Invests in banks

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Invests in financial instruments issued by banks

Finds funds that include financial instruments (cash, derivatives and / or foreign exchange) issued by banks. See fund literature for further information as strategies vary.

Invests in insurers

Funds that do or may invest in insurance companies.

Governance & Management
Avoids companies with poor governance

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UN sanctions exclusion

Exclude companies that are subject to United Nations sanctions. See eg https://main.un.org/securitycouncil/en/content/un-sc-consolidated-list

Encourage higher ESG standards through stewardship activity

A core element of these funds will aim to encourage higher ESG standards through responsible ownership / stewardship / engagement /voting activity

Asset Size
Invests in small, mid and large cap companies / assets

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How The Fund Works
Negative selection bias

Find funds where their main 'ethical approach' is to avoid companies by using negative screening criteria. Read fund literature for further information.

Data led strategy

Find funds that make stock selection (and ongoing fund management) decisions based on ESG data or company ratings (normally supplied by third parties) rather than focusing on what individual companies do, how they operate or their plans for the future

Combines norms based exclusions with other SRI criteria

Find funds that make significant use of internationally agreed 'norms' (e.g. United Nations Global Compact - UNGC - or the UN Sustainable Development Goals - SDGs) as part of their investment selection process alongside additional SRI criteria such as positive or negative stock selection policies and/or stewardship strategies.

Balances company 'pros and cons' / best in sector

Find funds that consider both the 'positive' and 'negative' aspects of company behaviour and make balanced, considered decisions as part of their investment approach. May apply to a range of different issues and policy areas.

Norms focus

Find funds that use internationally agreed standards, conventions and 'norms' to help direct where the fund can and cannot invest (e.g. the UN Global Compact, UN Sustainable Development Goals). Read fund literature for further information.

SRI / ESG / Ethical policies explained on website

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Fund uses unscreened ‘diversifiers’ to help manage risk

Fund invests in assets that have not passed its usual sustainability criteria or screening standards in order to help manage investment risk. This may be limited or significant. See literature.

Do not use stock / securities lending

This fund does not use stock lending for performance or risk purposes.

Unscreened Assets & Cash
Assets typically aligned to sustainability objectives 70 - 79%

The percentage of assets held within the fund that match the fund’s sustainability objectives and are not being held purely for risk management purposes, such as derivatives and cash equivalent assets.

Intended Clients & Product Options
Available via an ISA (OEIC only)

Find funds that are available via a tax efficient ISA product wrapper.

Fund Management Company Information

About The Business
Boutique / specialist fund management company

Find fund management companies that are smaller or specialise in particular areas - notably, ideally ESG related. Strategies vary.

Responsible ownership / stewardship policy or strategy (AFM company wide)

Finds fund management companies that have a published company wide stewardship, engagement and / or responsible ownership policy or strategy that covers all investments. Stewardship typically involves encouraging higher ESG standards through voting and dialogue.

ESG / SRI engagement (AFM company wide)

Find fund management companies that actively encourage higher 'environmental, social and governance' and/or 'sustainable and responsible investment' practices across investee companies - typically where the aim is to encourage positive change that is aligned with the best interests of investors. Strategies vary. See additional information and options.

Vote all* shares at AGMs / EGMs (AFM company wide)

Find fund managers that vote all* the shares they own at Annual General Meetings and Extraordinary General Meetings. A commitment to voting shares is a key indicator of 'responsible share ownership' demonstrating their support for or disagreement with management policy. (*situations can legitimately, occasionally occur where voting proves impossible, but in principle all shares should be voted.)

Responsible ownership policy for non SRI funds (AFM company wide)

Find funds run by fund managers that apply Responsible ownership or 'Stewardship' policies to all or most of their investment assets. This means active involvement (e.g. voting, dialogue) with the companies they invest in across funds (not normally limited to ethical or SRI options.) Read fund literature for further information.

Integrates ESG factors into all / most (AFM) fund research

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In-house diversity improvement programme (AFM company wide)

Finds organisations / fund managers that have an in-house (company wide) diversity improvement programme - meaning that they are working to ensure that within their own businesses they employ people from diverse backgrounds - often typically focused on ethnicity and/or sex.

Vulnerable client policy on website (AFM company wide)

Asset manager has information on their website that explains how they treat 'vulnerable clients' (as set out in FCA regulation)

Collaborations & Affiliations
PRI signatory

Find fund management companies that have signed up to the UN backed 'Principles of Responsible Investment'.

UKSIF member

Find fund management companies that are members of UKSIF - the UK Sustainable Investment and Finance association

Fund EcoMarket partner

Find fund management companies that have partnered with Fund EcoMarket - meaning that they are helping to improve access to information on sustainable and responsible investment by paying an annual fee to us which enables us to publish information for free. Partner funds are listed ahead of other funds and have their logos displayed.

Investment Association (IA) member

Fund management entity is a member of the Investment Association https://www.theia.org/

Resources
In-house responsible ownership / voting expertise

Find fund management companies that employ people to steer and support fund managers in voting shares at company AGM's and EGMs in ways that are consistent with encouraging higher ESG/sustainability standards.

Employ specialist ESG / SRI / sustainability researchers

Find a fund management company that directly employs specialist ESG/SRI/sustainability researchers or analysts. This allows asset managers to discuss environmental, social and governance risks and opportunities directly with companies.

Use specialist ESG / SRI / sustainability research companies

Find fund management companies that makes use of expert external research companies. This can help deliver specialist expertise and means resources are pooled with other investors.

Accreditations
UK Stewardship Code signatory (AFM company wide)

Find fund managers that are signatories to the FRC UK Stewardship Code, which sets out a framework for constructive investor / investee relations where fund managers are encouraged to behave like responsible, typically longer term 'company owners'.

Engagement Approach
Regularly lead collaborative ESG initiatives (AFM company wide)

Find fund management companies that regularly initiate or run industry wide (collaborative) investor projects aimed at raising environmental, social and governance standards amongst investee companies.

Engaging on climate change issues

Fund manager has stewardship /responsible ownership strategy that is focused on addressing climate change with investee assets.

Engaging with fossil fuel companies on climate change

Asset manager has a stewardship /responsible ownership strategy that involves working with fossil fuel companies on climate change related issues. See fund manager website for details.

Engaging on biodiversity / nature issues

The asset manager has a responsible ownership / stewardship strategy that focuses on biodiversity and nature issues relating to the assets they invest the aim of which will be to reduce harm and or deliver improvement. Strategies vary. https://tnfd.global

Engaging to encourage a Just Transition

Asset manager has a responsible ownership / stewardship strategy which means they are working to encourage the shift to more sustainable business practices in ways that respect and are sensitive to social issues and the impact change has on people effected by the changes that are taking place. https://www.transitionpathwayinitiative.org/ https://transitiontaskforce.net/

Engaging on human rights issues

Asset manager has responsible ownership / stewardship strategy in place which aims to address human rights issues in investee companies (and potentially their suppliers) with the aim of raising standards

Engaging on labour / employment issues

Asset manager has responsible ownership / stewardship strategy in place that aims to improve labour standards for the benefit of employees in investee companies (and potentially their suppliers)

Engaging on diversity, equality and / or inclusion issues

Asset management company has a stewardship strategy in place which involves working to raise diversity, equality and inclusion standards across investee assets

Engaging to stop modern slavery

working with the assets they hold to help stamp out modern slavery - where direct or indirect company employees are exploited for business benefits.

Engaging on governance issues

Fund managers have stewardship strategies in place that focus on improving governance standards across investee assets

Engaging on responsible supply chain issues

Has a stewardship / responsible ownership strategy that encourages responsible supply chain - ie the managers will discuss environmental, social and governance issues with investee companies with the aim of raising standards

Stewardship escalation policy

Escalation policies describe how a manager will proceed if stewardship / engagement activity is not successful in the short term.

Climate & Net Zero Transition
Net Zero commitment (AFM company wide)

Fund management organisations that have pledged to reduce their greenhouse gas emissions to ‘net zero’. Strategies vary - this area is changing rapidly.

Net Zero - have set a Net Zero target date (AFM company wide)

This asset management company has set a date by which they plan to achieve net zero greenhouse gas / CO2e emissions.

Encourage carbon / greenhouse gas reduction (AFM company wide)

Find fund management companies that are working with the companies they invest in to encourage reductions in carbon dioxide and other greenhouse gas emissions.

Carbon transition plan published (AFM company wide)

Finds organisations / fund managers that have a company wide carbon transition plan - meaning that they have plotted a path to how they will move away from activities that produce or use carbon based energy sources (that emit greenhouse gases) towards clean, alternative, renewable energy sources.

Working towards a ‘Net Zero’ commitment (AFM company wide)

Finds organisations / fund management companies that are in the process of working out how to make a ‘net zero commitment’ - meaning that when that is finalised they will have started the process of reducing their total greenhouse gas emissions to'zero'.

Committed to SBTi / Science Based Targets Initiative

See https://sciencebasedtargets.org/

Transparency
Publish responsible ownership / stewardship report (AFM company wide)

Find fund management companies that publish a report detailing their responsible investment ownership - also known as 'Stewardship' - activity.

Full SRI / responsible ownership policy information on company website

Find companies that publish information about their sustainable and responsible investment strategies on their company website.

Full SRI / responsible ownership policy information available on request

Find fund management companies that will supply information about their sustainable and responsible investment activity on request.

Publish full voting record (AFM company wide)

Fund management companies that publish a full record of how they vote their shares at AGMs (annual general meetings) and EGMs (extraordinary general meetings). Voting strategies have an important role to play encouraging higher environmental, social and governance standards.

Net Zero transition plan publicly available (AFM company wide)

This asset management company has published a plan that explains how they are going to achieve net zero greenhouse gas / CO2e emissions.

Comments

Please Note:

  • Controversial weapons avoidance policy (AFM company wide) - Our policy is to exclude manufacturers of the following weapons: anti-personnel mines, cluster munitions, chemical weapons, biological weapons, nuclear weapons, Incendiary weapon, non-detectable fragment, blinding laser weapons, white phosphorus weapons, depleted uranium weapons.

Sustainable, Responsible &/or ESG Policy:

Sustainable investment philosophy

We consider sustainable investment to be about investing with a clear intent to deliver environmental and/or social outcomes alongside generating a financial return. The strategies that follow the Newton sustainable investment framework seek to balance financial, social and environmental outcomes to support long-term shareholder returns.

Sustainable investment framework

This framework is focused on two main components: defining what is incompatible with a sustainable universe --‘sustainable investment restrictions’ and defining what constitutes a sustainable investment. The latter rests on an approach that focuses on key sustainable investment themes with underlying sustainable activities and how an investment is connected with this – through alignment or contribution measures.

Sustainable investment universe

The portfolio manager is responsible for applying the Newton sustainable investment framework and ensuring that the security is eligible following a review which is documented. The review determines whether the investment contributes towards one or more of the Newton sustainable investment themes (sustainable contributors) or demonstrates strong environmental and/or social practices that align with one or more of the Newton sustainable investment themes (sustainable aligners).

Sustainable contributors: These are companies that provide solutions (products and services) that address the most pressing environmental or social challenges. Our sustainable investment framework is applied through a series of measures, such as revenues from products relating to Renewable and low-carbon energy sources, resource efficiency, affordable housing, medical technology and healthy eating. As a measure of their contribution, each sustainable contributor must have at least 30% revenue exposure (in aggregate) from one of more of the sustainable activities, as defined in the sustainable investment framework, or have at least 30% capital expenditure (CAPEX) or operational expenditure (OPEX) aligned to the EU Taxonomy.

Sustainable aligners: These are companies that manage to a high standard the social and environmental issues relating from their direct operations and supply chains as well as integrate sustainability priorities into their business strategy. This is primarily about the internal management of a company’s operations and supply chain where we seek to invest in leaders or best-in-class industry players. Companies that integrate sustainability into their business strategy have committed explicitly to improving their environmental and social impacts by reducing negative externalities that is expected to lead to a transformation of their business models. The outcome of this mitigation and transformation of the negative externality results in a meaningful positive outcome for society and/or the environment.

These two classifications are guided by frameworks, developed, and maintained by the Newton RI team, ensuring robustness and consistency in order to identify the suitable sustainable investment propositions. The overall framework is reviewed regularly and may evolve over time with Newton’s own thinking as well as with regulatory development.

Sustainable investment restrictions*

The sustainable investment restrictions mainly seek to avoid investments in areas of significant social or environmental harm. These restrictions cannot be overridden.

Here we seek to avoid investments involved in areas of high negative externalities, those that cause significant long-term societal harm, investments that have been identified as having severe controversies and/or violating one or more of the ten UN Global Compact Principles covering areas including human rights, labour practices, corruption and the environment. We do not believe that exposure to such activities is aligned with our sustainable investment framework.

To identify these companies, we use a combination of external service providers including Bloomberg, ISS, RepRisk, CDP and Factset to inform our decisions. The sustainable investment restrictions are hard coded into the Newton trade process and any potential violations are caught in the pre-trade compliance checks. Revenue threshold parameters applied through these restrictions reflect just one part of our sustainable investment framework – a key part of this process is the additional research and analysis conducted by the investment team.

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Note: 1 Some strategies following the Newton Sustainable Investment process may choose to add to these exclusions – but may never subtract.
Source: Newton, 30 January 2025.

However, please note: revenue threshold parameters reflect just one part of our sustainable investment process – a key part of this process is the additional research and analysis conducted by the investment team.

Our process seeks to clearly distinguish between activities that are subject to hard exclusions versus those activities that sustainability portfolio managers may be able to invest in in certain circumstances (precautionary pool).

Precautionary pool

For areas that have been identified as having controversies or the potential to cause harm (such as fossil fuels other than thermal coal, animal welfare, conventional defence and nuclear power) but are not covered by the sustainable investment restrictions, portfolio managers are alerted, when considering such investments, to review the controversial activity through what is referred to as the 'precautionary pool'. The precautionary pool includes companies that have been flagged in relation to their involvement in heavy-emitting industries, hold exposures to activities that are restricted, but at lower revenue thresholds, and areas such as nuclear power and animal welfare, where there may be nuances in the investment case that are deemed important to be highlighted.

The full list of activities caught currently under the precautionary pool is included below:

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Note: 1 The RI team maintains a list of companies that are tagged under the ‘precautionary pool’. Portfolio managers are alerted to this pool in the sustainable investment documentation portal (the Newton ‘RI App’). The portfolio managers are encouraged to work with the RI adviser assigned to the portfolio, to ensure that the managers are comfortable that the investment is not in conflict with the objectives of their strategy.
Source: Newton, 30 January 2025.

Bonds

Market participants and credit rating agencies have been placing increasing importance on non-financial factors in determining credit ratings, and understanding default risk on the debt issued by sovereigns. We believe a country’s competitiveness is dependent on the availability and quality of economic, natural, human and institutional capital. Countries that allocate and act as stewards of these capital resources effectively are likely to experience stable long-term growth and show more economic resilience. We evaluate factors such as natural resource depletion, social cohesion and advancement, conflict and institutional strength in order to understand if the returns on offer from sovereign debt are justified given the risks attached.

Since we believe that the durability of a sovereign bond relates to a number of factors we seek to gain a holistic view of a country, taking into account the various positive and negative factors. We consider data from a range of sources including the World Bank, Transparency International, IMF, Yale University, Notre Dame Institute and others.

We do not apply thresholds when assessing each individual data source, but instead use relative thresholds at the aggregated data level. There are two parts to the calculation – one is the overall score and the other is the momentum. While the score is on a relative basis, momentum is fundamental in nature. All of the indicators are classified into the four capitals mentioned above and then are combined to calculate results at the country level. The country level score and momentum for all countries are categorized into three parts (For Score – Strong, Average and Weak, For Momentum – Positive, Stable and Negative) which then allows for these countries to be allocated into a 3x3 matrix. Each quarter, the model is reviewed by the fixed income and RI specialists to assess whether current affairs have changed our outlook described within the matrix.

Those countries rated ‘weak’ and which do not have positive momentum cannot be included in our sustainable investment strategies. Those countries rated ‘average’ (irrespective of momentum) and ‘weak’ with positive momentum can only be included in the sustainable strategies subject to further work being completed by the sovereign specialist and subsequently agreed by the RI team.

Resources, Affiliations & Corporate Strategies:

Newton has a centralised responsible investment team. This team is the centre of excellence for all matters related to responsible investment, and with its deep functional knowledge of the responsible investment space and how it is evolving, it provides guidance, support and subject-matter expertise to our wider investment team. The responsible investment team, as you can see below, is global in its footprint and diverse in its employee base. The team is organised into three pillars of expertise – stewardship, research and analytics: these specialisations under the responsible investment umbrella allow us to bring further depth and expertise to each of these activities. The team’s compact size enables it to work cohesively and operate as one team.

Stewardship: Oversees the firm’s engagement framework and advocacy initiatives, focusing its efforts on meaningful outcomes for clients, and also undertakes the firm’s proxy voting activities. Provides subject-matter expertise to the investment team on governance risks and evolving expectations.

Sustainability research: Subject-matter experts consulting the investment and research teams, driving deep insights on sustainability-related subjects. The team manages Newton’s sustainability standards, definitions and frameworks.

Responsible investment analytics: Has strong quantitative and RI data expertise and owns the data ecosystem, creating and managing responsible investment data models, frameworks and tools that support ESG integration and sustainable investing. The team has built an innovative suite of building blocks that can be leveraged to develop scalable solutions to meet specific client requirements.

The role of the responsible investment team is to be a support function to the investment teams, to set standards around sustainable investment, and to coordinate and ensure effectiveness around our stewardship efforts. It guides the business around policies and direction of travel for sustainability and stewardship more broadly. The responsible investment team also owns and manages the overall governance systems to ensure we deliver against key codes and commitments including stewardship codes, industry principles such as the UN Principles for Responsible Investment, and industry pledges such as the Net Zero Asset Managers Initiative (NZAMi).

Supporting the team, and the wider business, are various external organisations and vendors including ESG service providers, memberships, and internal systems for monitoring and reporting.

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Affiliations
As investors and an intermediary in the financial system we play an important role in providing investors with access to investment solutions, and that with this comes an inherent responsibility to do what is right on behalf of our clients, as well as wider asset owners and stakeholders in the financial system. Our advocacy focus involves supporting or seeking to influence various issues and areas for the long-term interest of our clients and Newton.

Organisations and initiatives related to responsible investment matters in which Newton plays a formal role:

*Newton Japan was established as a legal entity in March 2023. Its prior commitment to the Japan Stewardship Code was under its previous structure.

ESG Governance

Having an effective management and governance framework is an important part of our overall business strategy. As investors, we understand the value of effective leadership and accountability. This is closely linked to the culture of our business, as leadership and accountability have equal importance in Newton’s governance. We have therefore established appropriate governance systems and controls to support our stewardship and RI policy. This policy is reviewed and approved by the Newton Sustainability Committee (NIM and NIMNA), which reports to the Newton Executive Management Committee (NEMC) (to note, the NEMC reports into NIM and NIMNA boards). The policy is also reviewed and approved by the NIMJ Investment Oversight Committee, which reports into the NIMJ Executive Management Committee. The NEMC has overall responsibility for defining Newton’s approach, values and actions across all Newton entities.

Two of our operating committees play important roles in relation to our stewardship and RI efforts:

  • Newton Sustainability Committee – oversees all aspects relating to stewardship and RI at NIM and NIMNA, including our investments, direct impacts and engagement with communities, and engagement with the wider market (advocacy) regarding RI and stewardship matters.
  • Newton Risk and Compliance Committee – supported by the Newton Conflicts of Interest Committee and the Emerging Risks Working Group.

These committees deal with various stewardship and RI aspects on an ad-hoc basis, including any relevant internal audit findings and actions as well as climate-related risk updates from internal groups.

Our Board Risk Committee also plays a role in the governance of our RI and stewardship efforts; it acts as an escalation point for any material issues identified through our governance systems and controls. For example, it has previously considered materials related to climate risk. We have also established the Newton Sustainable Investment Forum (SIF) as an oversight group to monitor our strategies with sustainability characteristics.

The role of the SIF is to:

  • Foster debate by bringing together a wider set of Newton investment team members focusing on sustainability, including sustainability portfolio managers and RI team members
  • Provide support by educating, training and sharing knowledge and insights among the investment team.

SDR Labelling:

Unlabelled with sustainable characteristics

Disclaimer

IMPORTANT INFORMATION
Past performance is not a guide to future performance.
The value of investments can fall. Investors may not get back the amount invested.
Income from investments may vary and is not guaranteed.
For Professional Clients only.
Provided solely for use by Fund Ecomarket.
BNY, BNY Mellon and Bank of New York Mellon are the corporate brands of The Bank of New York Mellon Corporation and may be used to reference the corporation as a whole and/or its various subsidiaries generally.
Issued in the United Kingdom by BNY Mellon Investment Management EMEA Limited, BNY Mellon Centre, 160 Queen Victoria Street, London EC4V 4LA. Registered in England No. 1118580. Authorised and regulated by the Financial Conduct Authority.
Newton global assets under management (AUM) is the combined total assets under management of Newton Investment Management Limited (‘NIM’), Newton Investment Management North America LLC (‘NIMNA’) and Newton Investment Management Japan Limited (‘NIMJ’).
Returns may increase or decrease as a result of currency fluctuations.
Costs incurred when purchasing, holding, converting or selling any investment, will impact returns.
Costs may increase or decrease as a result of currency and exchange rate fluctuations.

Newton manages a variety of investment strategies. How ESG analysis is integrated into Newton’s strategies depends on the asset classes and/or the particular strategy involved. ESG can be one of many inputs into the fundamental analysis. Newton will make investment decisions that are not based solely on ESG analysis. Other attributes of an investment may outweigh ESG analysis when making investment decisions.

*Newton’ and/or ‘Newton Investment Management’ is a corporate brand which refers to the following group of affiliated companies: Newton Investment Management Limited (“NIM”), Newton Investment Management North America LLC (“NIMNA”) and Newton Investment Management Japan Limited ("NIMJ").

Newton’s assets under management include assets collectively managed by NIM, NIMNA and NIMJ. In addition, AUM for Newton includes assets of bank-maintained collective investment funds for which Newton has been appointed sub-advisor, where Newton personnel act as dual officers of affiliated companies and assets of wrap fee account(s) for which Newton provides sub-advisory services to the primary manager of the wrap program.

For a full list of risks applicable to this fund, please refer to the Prospectus or other offering documents.
Please refer to the prospectus, and the KIID/KID before making any investment decisions. Go to www.bnymellonim.com
The Funds are sub-funds of BNY Mellon Investment Funds, an open-ended investment company with variable capital (ICVC) with limited liability between sub-funds. Incorporated in England and Wales: registered number IC27. The Authorised Corporate Director (ACD) is BNY Mellon Fund Managers Limited (BNY MFM), incorporated in England and Wales: No. 1998251. Registered address: BNY Mellon Centre, 160 Queen Victoria Street, London EC4V 4LA. Authorised and regulated by the Financial Conduct Authority.
Fund performance calculated as total return, including reinvested income net of UK tax and charges, based on net asset value. All figures are in GBP terms. The impact of an initial charge (currently not applied) can be material on the performance of your investment. Further information is available upon request.
Returns may increase or decrease as a result of currency fluctuations.
Costs incurred when purchasing, holding, converting or selling any investment, will impact returns.
Costs may increase or decrease as a result of currency and exchange rate fluctuations.

Benchmark: The Fund will measure its performance before fees against SONIA (30-day compounded) on a rolling annualised 3 year basis (the "3 year Benchmark") and SONIA (30-day compounded) +4% per annum on a rolling annualised 5 year basis (the "5 year Benchmark"). SONIA is a nearly risk-free rate meaning no bank credit risk is included, the rate can rise or fall as a result of central bank policy decisions or changing economic conditions. The Fund will use the 3 year Benchmark as a lower threshold for the Fund's performance to match or exceed over a rolling 3 year period, as it is representative of cash; and the 5 year Benchmark as an upper threshold for its performance to match or exceed over a rolling annualised 5 year basis, as it is consistent with the level of risk that the Fund takes. The Fund is actively managed, which means the Investment Manager has discretion over the selection of investments, subject to the investment objective and policies as disclosed in the Prospectus.
Newton manages a variety of investment strategies. How ESG analysis is integrated into Newton’s strategies depends on the asset classes and/or the particular strategy involved. ESG can be one of many inputs into the fundamental analysis. Newton will make investment decisions that are not based solely on ESG analysis. Other attributes of an investment may outweigh ESG analysis when making investment decisions.

KEY INVESTMENT RISKS
Objective/Performance Risk: There is no guarantee that the Fund will achieve its objectives. Currency Risk: This Fund invests in international markets which means it is exposed to changes in currency rates which could affect the value of the Fund. Derivatives Risk: Derivatives are highly sensitive to changes in the value of the asset from which their value is derived. A small movement in the value of the underlying asset can cause a large movement in the value of the derivative. This can increase the sizes of losses and gains, causing the value of your investment to fluctuate. When using derivatives, the Fund can lose significantly more than the amount it has invested in derivatives. Counterparty Risk: The insolvency of any institutions providing services such as custody of assets or acting as a counterparty to derivatives or other contractual arrangements, may expose the Fund to financial loss. Charges to Capital: The Fund takes its charges from the capital of the Fund. Investors should be aware that this has the effect of lowering the capital value of your investment and limiting the potential for future capital growth. On redemption, you may not receive back the full amount you initially invested. Responsible Investing Risk: The investment policy for this Fund places restrictions on its exposure to certain sectors or types of investments to reflect its responsible investing approach. The Fund's performance may be negatively impacted due to these restrictions in comparison to funds which do not have these restrictions. The Fund will not engage in securities lending activities and, therefore, may forego any additional returns that may be produced through such activities. Performance Aim Risk: The performance aim is not a guarantee, may not be achieved and a capital loss may occur. Funds which have a higher performance aim generally take more risk to achieve this and so have a greater potential for returns to vary significantly. Changes in Interest Rates & Inflation Risk: Investments in bonds/ money market securities are affected by interest rates and inflation trends which may negatively affect the value of the Fund. Credit Ratings and Unrated Securities Risk: Bonds with a low credit rating or unrated bonds have a greater risk of default. These investments may negatively affect the value of the Fund. Credit Risk: The issuer of a security held by the Fund may not pay income or repay capital to the Fund when due. Emerging Markets Risk: Emerging Markets have additional risks due to less-developed market practices. Shanghai-Hong Kong Stock Connect and/or the Shenzhen-Hong Kong Stock Connect ("Stock Connect") risk: The Fund may invest in China A shares through Stock Connect programmes. These may be subject to regulatory changes and quota limitations. An operational constraint such as a suspension in trading could negatively affect the Fund's ability to achieve its investment objective. China Interbank Bond Market and Bond Connect risk: The Fund may invest in China interbank bond market through connection between the related Mainland and Hong Kong financial infrastructure institutions. These may be subject to regulatory changes, settlement risk and quota limitations. An operational constraint such as a suspension in trading could negatively affect the Fund's ability to achieve its investment objective. CoCo's Risk: Contingent Convertible Securities (CoCo's) convert from debt to equity when the issuer's capital drops below a pre-defined level. This may result in the security converting into equities at a discounted share price, the value of the security being written down, temporarily or permanently, and/or coupon payments ceasing or being deferred. Investment in Infrastructure Companies Risk: The value of investments in Infrastructure Companies may be negatively impacted by changes in the regulatory, economic or political environment in which they operate. A complete description of risk factors is set out in the Prospectus in the section entitled "Risk Factors"