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Information Classification: General
State Street Global Dividend Spotlight Active
Equity UCITS ETF - Website disclosure for an
Article 8 fund
A . Summary
The objective of the State Street State Street Global Dividend Spotlight Active Equity UCITS ETF (the “ Fund ”) is to generate capital growth over the long term t hrough investment in global equity securities .
The Fund promotes environmental or social characteristics and while it does not have as its objective a sustainable investment , it will seek to invest a minimum of 25% of its portfolio in sustainable investments under article 2(17) of SFDR using the Investment Manager’s proprietary assessment methodology .
The Fund promotes environmental characteristics related to reduction of environmental footprint and adverse social impacts by excluding investments in companies that are involved in thermal coal, A rctic oil & gas exploration, oil sands extraction, severe ESG controversies , as well as the companies which violate United Nations Global Compact (“ UNGC ”) principles (the “ UNGC Principles ”) relating to the environment (principles 7 to 9).
The Fund promotes social characteristics related to: (a) reduction of the availability of weapons by excluding investment in companies associated with controversial weapons and civilian firearms , (b) reduction of adverse health impacts by excluding investment in companies associated with tobacco, (c) support for human rights, labour standards and anti - corruption by excluding investment in companies which violate UNGC Principles relating to human r ights (Principles 1 and 2), labour (principles 3 to 6) and an ti - corruption (principle 10) as well as companies associated with severe ESG controversies.
The Fund also promotes the following environmental and social characteristics related to the reduction of carbon emissions by seeking to invest in companies such that the Fund’s portfolio overall exhibits lower carbon emissions than the Index as measured using Weighted Average Carbon Intensity (“ WACI ”).
The Investment Manager employs a binding ESG methodology which aims to build a portfolio where at least 90% of the Fund’s assets are invested in securities which are aligned with environmental and social characteristics promoted by the Fund. It is intended that, within such portion of the portfolio, at least 25% of the Fund’s assets are invested in securities which are sustainable investments with environmental and / or social objectives. The remaining portion (<10%) of the portfolio, consisting of cash as well as cash equivalents , including financial derivative instruments employed for efficient portfolio management or hedging purposes, held at the Investment Manager’s discretion , will not be aligned with the promoted environmental and social characteristics. To the extent that the Fund may use financial derivative instruments, these will not be used to attain the environmental or social characteristics promoted by the Fund.
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Information Classification: General
The Fund does not commit to making sustainable investments within the meaning of the Taxonomy Regulation.
The attainment of the environmental characteristics is measured through achieving a higher exposure of the Fund’s portfolio to companies such that the Fund’s overall portfolio exhibits lower carbon emissions (relative to the Index as measured using WACI ) . A further attainment of the environmental and social characteristics promoted by the fund is measured through the % of the portfolio invested in securities that are included in the negative and norms based screen.
In order to attain the environmental and social characteristics promoted by the Fund, the Investment Manager implements the uses a proprietary fundamentally driven and bottom up research process to build a concentrated portfolio of 30 - 40 securities for the Fund while evaluating an investee company’s carbon emissions . In addition, t he Investment Manager also applies a negative and norms - based ESG screen prior to the construction of the portfolio and on an ongoing basis . The Fund will screen out securities of issuers that fail to comply with UNGC Principles relating to environmental protection, human rights, labour standards and a nti - corruption or are associated with severe ESG controversies, controversial weapons, civilian firearms, tobacco, thermal coal, A rctic oil & gas exploration, and oil sands extraction.
The Fund uses the following data sources: 1. ISS for WACI Metric 2. MSCI and Sustainalytics for ESG screens
State Street Investment Management implements an ongoing due diligence process in relation to sustainability data providers resulting in regular data quality report s and may engage with the relevant data providers in relation to any data issues identified.
Sustainability data may be based on certain assumptions, forecasts, projections, views and opinions which may be based on current market trends or anticipated future events. Given the developing and innovative nature of data models, methodologies and assumptions and the inherent uncertainty in predicting forward - looking events, it cannot be guaranteed that the sustainability data is always accurate or correct or that the sustainability data will satisfy the aims or requirements of any specific client or inv estor. Furthermore, there may be data that cannot be sourced due to the lack of availability of data sources.
While engagement policies are not directly embedded into the Fund’s investment strategy, proxy voting and engagement activities in respect of securities held by the Fund are conducted pursuant to the terms of the Sustainability Stewardship Service Proxy Voting and Engagement Policy (the “ Sustainability Policy ”). The Sustainability Policy focuses on risks and opportunities that may impact long - term value creation, with a focus on sustainability priorities such as climate change, nature, human rights and diversity.
For further information and details please refer to the relevant sections below, the Prospectus and Relevant Supplement .
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Information Classification: General
B. No sustainable investment objective
The Fund promotes environmental or social characteristics and while it does not have as its objective a sustainable investment , it will seek to invest a minimum of 25% of its portfolio in sustainable investments under article 2(17) of SFDR using the Investment Manager’s proprietary assessment methodology .
Sustainable investments that the financial product partially intends to make should not cause significant harm to any environmental or social sustainable investment objective. In this respect, the Investment Manager considers the mandatory principal advers e indicators (“ PAIs ”) on sustainability factors by combining the incorporation of the SASB materiality framework in the Investment Manager’s Sustainability Rating and the application of the negative and norms - based screens to the sustainable investments included in the Fund’s portfolio. By investing in securities classified as “Leaders or Outperformers” in accordance with the Investment Manager’s Sustainability Rating and applying the relevant negative and norms - based screens, the Investment Manager deems the Fund’s susta inable investments not to cause significant harm to any environmental or social sustainable investment objective.
The Fund pursues a reduction of negative externalities caused by the underlying investments and in that context considers PAI s on sustainability factors as part of the consideration of sustainable investments in selecting the securities for the Fund and by applying the negative and norms - based ESG screen prior to the construction of the portfolio. Specifically, the Fund considers:
• Exposure to companies active in the fossil fuel sector
• Violations of UN GC Principles • Exposure to controversial weapons.
The Fund excludes companies that the Investment Manager has deemed to violate UNGC P rinciples as part of the negative screening utilised by the Fund. The OECD Guidelines for Multinational Enterprises and the UN Guiding Principles on Business and Human Rights are considered as part of the UNGC P rinciples assessment.
C . Environmental or social characteristics of the financial product
The Fund promotes environmental characteristics related to reduction of environmental footprint and adverse social impacts by excluding investments in companies that are involved in thermal coal, A rctic oil & gas exploration, oil sands extraction, severe ESG controversies , as well as the companies which violate UNGC Principles relating to the environment (principles 7 to 9).
The Fund promotes social characteristics related to: (a) reduction of the availability of weapons by excluding investment in companies associated with controversial weapons and civilian firearms , (b) reduction of adverse health impacts by excluding investment in companies associated with tobacco, (c) support for human rights, labour standards and anti - corruption by excluding investment in companies which violate UNGC Principles relating to human r ights (Principles 1 and 2), labour
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Information Classification: General
(principles 3 to 6) and anti - corruption (principle 10) as well as companies associated with severe ESG controversies.
The UNGC Principles is the world largest corporate sustainability initiative aimed at companies to align their strategies and operations with universal principles on human rights, labour, environment and anti - corruption, and take actions that advance socie tal goals.
Business involvement: The definition of “involved” in relation to each activity, as set out above, is determined using the Investment Manager’s proprietary methodology. Each activity may be based on generating or deriving a revenue from the activity that e xceeds a percentage of revenue or a defined total revenue threshold, or any exposure to the activity regardless of the amount of revenue received. The activity may relate to production or distribution or both in accordance with the Investment Manager’s pro prietary methodology. For certain industries the Investment Manager applies a maximum percentage thresholds typically based on revenue from production and/or distribution (which can vary depending on whether the issuer is a producer, distributor or service provider). Please refer to section G for more details.
The specific list of applicable exclusions may evolve and may be amended from time to time by the Investment Manager , subject to complying with the Central Bank’s requirements .
The Fund also promotes the following environmental and social characteristics related to the reduction of carbon emissions by seeking to invest in companies such that the Fund’s portfolio overall exhibits lower carbon emissions than the Index as measured u sing WACI.
The Fund allocates minimum 25% of the Fund’s portfolio to sustainable investments. In order for the security to qualify as a sustainable investment for the Fund, it must be classified as a “Leader” or “Outperformer” as determined by the Investment Manager . A “Leader” or “Outperformer” is defined as a security within the top 30th percentile of the Investment Manager’s sustainability coverage universe, as determined by the Investment Manager using the Sustainability Rating generated by its proprietary process .
For further details of the exclusions applied by the Investment Manager at any time please refer to Section G below.
D . Investment Strategy
The Investment Manager, on behalf of the Fund, will invest actively using a proprietary fundamentally driven and bottom up research process to identify companies with a meaningful dislocation between the assessed intrinsic value of the company and the price of its equity security. This opportunity set is used to construct a bala nced global portfolio of 30 - 40 securities which the Investment Manager believes has the potential to provide excess returns. In selecting investments, the Investment Manager will not have any specific geographic or sector focus.
The Investment Manager will use an active investment strategy which uses a fundamentally driven and bottom - up research process to identify companies with a dislocation between the intrinsic value of the company and the price of its equity security. This wi ll involve in - depth company and industry
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Information Classification: General
research by experienced sector analysts within the Investment Manager which will be applied to evaluate the future cashflow generation of a business and hence determine its intrinsic value. Areas that are typically researched include, inter alia, the overa ll industry structure, competitive dynamics and growth levels, the company’s competitive position, moat (a company’s ability to maintain a competitive edge over its competitors) and growth prospects, management’s strategy and experience, governance and th e financial resilience of the business.
In implementing this strategy, the Investment Manager applies the negative and norms - based ESG screen prior to the construction of the portfolio of the Fund and on an ongoing basis. The Fund will screen out securities of issuers that fail to comply with UN GC Principles relating to environmental protection, human rights, labour standards and anti - corruption or are associated with severe ESG controversies, controversial weapons, civilian firearms, tobacco, thermal coal, A rctic oil & gas exploration, and oil s ands extraction. Finally, the carbon emissions of the portfolio will be maintained below that of the Benchmark, as measured by WACI.
The Fund may use additional ESG screens from time to time in order to exclude securities of issuers based on their involvement with an activity that is deemed non - compliant with one or more of such ESG criteria referred to.
The assessment of good governance practices is considered by the Investment Manager as part of the assessment of potential investments when implementing the investment objective and policy of the Fund. The Investment Manager deploys a proprietary governanc e assessment framework that includes a governance scorecard and a qualitative assessment. The framework considers factors such as board independence, diversity and experience as well as the configuration of executive compensation and accounting and tax com pliance. The assessment of good governance practices is further implemented through the negative screening utilised by the Fund. Companies deemed by the Investment Manager not to violate UNGC principles are considered to exhibit good governance.
E . Proportion of investments
The Investment Manager employs a binding ESG methodology which aims to build a portfolio where at least 90% of the Fund’s assets are invested in securities which are aligned with environmental and social characteristics promoted by the Fund. It is intended that, within such portion of the portfolio, at least 25% of the Fund’s assets are invested in securities which are sustainable investments with environmental and / or social objectives. The remaining portion (<10%) of the portfolio, consisting of cash as well as cash equivalents, including financial derivative instruments employed for efficient portfolio management or hedging purposes, in place held at the Investment Manager’s discretion, will not be aligned with the promoted environmental and social char acteristics.
The Fund does not explicitly commit to a separate allocation for socially sustainable investments distinct from environmentally sustainable investments. This approach reflects the Fund's broader ESG strategy, which integrates both environmental and social considerations within its sustainable investment criteria.
To the extent that the Fund may use , for efficient portfolio management purposes only, financial derivative instruments, these will not be used to attain the environmental or social characteristics promoted by the Fund.
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Information Classification: General
The Fund does not commit to making sustainable investments within the meaning of the Taxonomy Regulation.
F . Monitoring of environmental or social characteristics
The attainment of the environmental characteristics is measured through achieving a higher exposure of the Fund’s portfolio to companies such that the Fund’s overall portfolio exhibits lower carbon emissions (relative to the Index) as measured using WACI.
A further attainment of the environmental characteristics promoted by the Fund is measured through: • % of the portfolio invested in securities violating UNGC Principles in regards to the environment and which are active in thermal coal, A rctic oil & gas exploration, and oil sands extraction. The level of exposure to such securities is anticipated to be 0% in respect of the proportion of securities which meet the criteria for business involvement as set out above.
The attainment of the social characteristics promoted by the Fund is measured through: • % of the portfolio invested in securities that are violating UNGC Principles and companies associated with controversial weapons, civilian firearms, tobacco and severe ESG controversies. The level of exposure to such securities is anticipated to be 0% in respect of the proportion of securities which meet the criteria for business involvement as set out above.
The environmental and social characteristics are embedded in the investment policy of the Fund and the associated sustainability indicators are monitored by the Investment Manager through its investment oversight program including pre and post - trade compli ance monitoring for ESG screens and regular reviews by a sub - committee of the Investment Manager.
G. Methodologies
The investment objective of the Fund is to seek to outperform the performance of the Index over the long term.
ESG Screens
The ESG screens applied to the Fund include the following: 1. Controversial Weapons 2. UNGC Violations 3. Thermal Coal 4. Arctic Drilling 5. Oil Sands 6. Severe ESG Controversies 7. Civilian Firearms 8. Tobacco
Further details on the methodologies used for the ESG screens is as follows:
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Information Classification: General
1. Controversial Weapons: The following types of weapons are covered by State Street Investment Management’s screen:
• Cluster munitions • Antipersonnel mines and land mines • Biological and chemical weapons • Nuclear Weapons • Depleted Uranium • Incendiary weapons and white phosphorus • Blinding laser weapons • Non - detectable fragments
Indicator Definition Controversial weapons noted above for which: There is evidence of activity The weapon is a core weapon system or a core weapon activity The product has a dedicated scope The scope is key to the production of the weapon
The company is involved in the core weapon system, or components/ services of the core weapon system that are considered tailor - made and essential for the lethal use of the weapon.
Any controversial weapon for a subsidiary that the company has >= 50% ownership of
The company is involved, through corporate ownership, in the core weapon system, or components/services of the core weapon system that are considered tailor - made and essential for the lethal use of the weapon. Cluster Munitions Manufacturer = True
Companies that produce cluster munitions whole weapons systems, intended - use components, dual - use components, or delivery platforms. Land mines Manufacturer = True
Companies that produce whole weapons systems or essential intended or dual - use c o mponents for anti - personnel landmines and anti - vehicle landmines. Nuclear Weapons Manufacturer Maximum Revenue Percentage >= 10%
The company's reported revenue (or, where not disclosed, maximum estimated revenue) from nuclear weapons, intended and dual - use components for such products, delivery platforms capable of deploying nuclear weapons, essential components for such delivery platforms, and support services for such products as a percentage of total revenue in its most recently completed fiscal year. Depleted Uranium Manufacturer = True
Companies involved in the production of depleted uranium weapons, ammunition and armo u r. Incendiary Weapons (White Phosphorous) = True
Companies that produce incendiary weapons using white phosphorus.
Biological/Chemical Weapons Maximum Revenue Percentage >= 10%
The company’s reported revenue (or, where not disclosed, maximum estimated revenue) from the production of biological and chemical weapons and components for such products as a percentage of total revenue in its most recently completed fiscal year. Blinding laser weapons = True Companies that produce blinding laser weapons, that cause permanent blindness t Non - detectable fragments = True
Companies that produce weapons that use non - detectable fragments.
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Information Classification: General
2. UNGC Principles: The UNGC is the world’s largest corporate sustainability initiative. It sets forth 10 responsible business principles for companies to follow. Companies who are in violation of the UNGC Principles are screened.
Human Rights
Principle 1: Businesses should support and respect the protection of internationally proclaimed human rights .
Principle 2: They should make sure that they are not complicit in human rights abuses.
Labour
Principle 3: Businesses should uphold the freedom of association and the effective recognition of the right to collective bargaining .
Principle 4: They should promote the elimination of all forms of forced and compulsory labour .
Principle 5: They should endorse the effective abolition of child labour .
Principle 6: They should support t he elimination of discrimination in respect of employment and occupation.
Environment
Principle 7: Businesses should support a precautionary approach to environmental challenges .
Principle 8: They should undertake initiatives to promote greater environmental responsibility .
Principle 9: They should encourage the development and diffusion of environmentally friendly technologies.
Anti - Corruption
Principle 10: Businesses should work against corruption in all its forms, including extortion and bribery.
Indicator Definition Global compact principles breached = Noncompliant
A company is assessed as Noncompliant when it is found to be responsible for egregious and severe violations of commonly accepted intern a tional norms related to human rights, labor rights, the environment and business ethics. In other words, a company is assessed as Noncompliant when it does not act in accordance with the UN Global Compact Principles and its associated standards, conventions and treaties. The data provider also assesses companies that facilitate third parties in human rights violations due to their
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Information Classification: General
involvement in weapons with disproportional and/or nondiscriminatory impact on citizens and society as Noncompliant (with Principle 2 of the UN Global Compact). However, this assessment is limited to companies involved in the production and development of antipersonnel mines, cluster munitions, and chemical and biological weapons, or producers of nuclear weapons who support their proliferation outside of the five designated nuclear states or who violate UN sanctions/ International Atomic Energy Agency rules.
3. Thermal Coal: Companies involved in the extraction or power generation of thermal coal are excluded.
Indicator Definition Thermal Coal Extraction >=10% The company derives revenue from thermal coal extraction Thermal Coal Power Generation >=10%
The company derives revenue from generating electricity from thermal coal.
4. Arctic Drilling: Companies involved in oil and gas exploration in the Arctic regions are excluded.
Indicator Definition Arctic Oil and Gas Exploration , level of involvement >=10%
The company derives revenue from oil and gas exploration and extraction in the Arctic .
5. Oil Sands: Companies for whom a meaningful portion of their average daily production comes from oil sands are excluded.
Indicator Definition Oil Sands Extraction , level of involvement >=10%
The company derives revenue from the extraction of oil sands.
6. Severe ESG Controversies: Companies involved in incidents/events that may pose business or reputational risk due to the potential impact on stakeholders, the environment, or the company’s operations are excluded.
Indicator Definition Category 5 — Severe Controversies
The event has a severe impact on the environment and society, posing serious business risks to the company. This category represents exceptionally egregious corporate behavior, high frequency of recurrence of incidents, very poor management of sustainabili ty - related risks, and a demonstrated lack of willingness by the company to address such risks.
7. Civilian Firearms : Companies involved in the manufacturing and/or retailing of small arms and associated ammunition/components for civilian use are excluded.
Indicator Definition Small Arms, Civilian Customers, Assault Weapons , level of involvement >=10%
The company derives revenue from manufacturing and selling small arms to civilian customers .
Manufacture of key components, level of involvement >=10%
The company derives revenue from manufacturing and selling key components of small arms .
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Information Classification: General
Small Arms, Retail and Distribution of Assault Weapons , level of involvement >=10%
The company derives revenue from retailing and/or distribution of small arms .
Firearms Production Maximum Revenue >=10%
The company’s reported revenue (or, where not disclosed, maximum estimated revenue) from the production of firearms and small - arms ammunition intended for civilian markets as a percentage of total revenue in its most recently completed fiscal year. Firearms Retailer Maximum Revenue >=10%
The company’s reported revenue (or, where not disclosed, maximum estimated revenue) from the wholesale or retail distribution of firearms or small - arms ammunition intended for civilian use as a percentage of total revenue in its most recently completed fiscal year.
8. Tobacco : Companies tha t are involved in the production , manufacturing , retailing and/or distribution of tobacco and tobacco - related products /services (including vaping, pipes and other related products) are excluded.
Indicator Definition Tobacco Production, Level of Involvement >=10%
The company derives revenue from the production of tobacco and tobacco - related products . Tobacco Production Maximum Revenue Percentage >= 10%
The company derives revenue from the distribution and/or retail sale of tobacco products. Tobacco products related products/services, level of involvement >= 25%
The company supplies tobacco - related products/services.
T obacco production maximum revenue >= 10%
The company’s reported revenue (or, where not disclosed, maximum estimated revenue)from the production of tobacco products as a percentage of total revenue in its most recently completed fiscal year. Tobacco products include nicotine containing products, including traditional and alternative tobacco smoking products. Tobacco retailer maximum revenue >= 25%
The company’s reported revenue (or, where not disclosed, maximum estimated revenue) from the retail of tobacco products as a percentage of total revenue in its most recently completed fiscal year. Tobacco products include nicotine - containing products, including traditional and alternative tobacco smoking products. Tobacco distributor maximum revenue >= 25%
The company’s reported revenue (or, where not disclosed, maximum estimated revenue) from the distribution of tobacco products as a percentage of total revenue in its most recently completed fiscal year. Tobacco products include nicotine containing products, including traditional and alternative tobacco smoking products.
The exclusion list generated by the ESG screening process is updated once per quarter .
The ESG screen methodology and screening criteria applied to the Fund are subject to S tate Street Investment Management ’s governance approval process .
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Information Classification: General
H . Data sources and processing
The Fund utilises the following data sources • ISS for WACI metric
The Fund utilises the following data sources to derive the ESG screens:
Controversial Weapons State Street Investment Management receives universe - level data from two ESG screening data providers: Sustainalytics and MSCI. A screen is then applied to the data to generate lists from each data provider of excluded securities for this category. State Street Investment Management determines the parameters that define the screen which are then approved by the firm’s governance process. Companies are excluded if they appear on either or both of the lists from the two data providers.
UNGC Violations Data is sourced from Sustainalytics. A screen is then applied to the data to generate a list of excluded securities for this category. State Street Investment Management determines the parameters that define the screen which are then approved by the firm’s governance process.
Thermal Coal Data is sourced from Sustainalytics. A screen is then applied to the data to generate a list of excluded securities for this category. State Street Investment Management determines the parameters that define the screen which are then approved by the firm’s governance process.
Arctic Drilling Data is sourced from Sustainalytics. A screen is then applied to the data to generate a list of excluded securities for this category. State Street Investment Management determines the parameters that define the screen which are then approved by the firm’s governance process.
Oil Sands Data is sourced from Sustainalytics. A screen is then applied to the data to generate a list of excluded securities for this category. State Street Investment Management determines the parameters that define the screen which are then approved by the firm’s governance process.
Severe ESG Controversies Data is sourced from Sustainalytics. A screen is then applied to the data to generate a list of excluded securities for this category. State Street Investment Management determines the parameters that define the screen which are then approved by the firm’s governance process.
Civilian Firearms State Street Investment Management receives universe - level data from two ESG screening data providers: Sustainalytics and MSCI. A screen is then applied to the data to generate lists from each data provider of excluded securities for this category. State Street Investment Management determines the parameters that define the screen which are then approved by the firm’s governance process. Companies are excluded if they appear on either or both of the lists from the two data providers.
Tobacco State Street Investment Management receives universe - level data from two ESG screening data providers: Sustainalytics and MSCI. A screen is then applied to the data to generate lists from each data provider of excluded securities for this category. State Street Investment Management determines the parameters that define the screen which are then approved by the firm’s governance
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Information Classification: General
process. Companies are excluded if they appear on either or both of the lists from the two data providers .
State Street Investment Management receives sustainability data from a wide variety of data providers covering various themes including, but not limited to, climate, controversies and governance and leverages multisource data architecture for the analysis and dissemination of sustainability data .
State Street Investment Management implements an ongoing due diligence process in relation to sustainability data providers resulting in regular data quality reports. Such process tracks correlation and coverage dimensions of key sustainability and climate metrics and scores between a selection of data providers over time for the covered universe. State Street Investment Management may engage with the relevant data providers in relation to any data issues identified.
I. Limitations to methodologies and data
Sustainable investing data may be based on certain assumptions, forecasts, projections, views and opinions which may be based on current market trends or anticipated future events. To assess company involvement in different activities and to estimate revenue shares as accuratel y as possible, data providers strive to obtain information directly from companies and issuers. Sources of data include annual reports, regulatory filings, sustainability reports, press releases, investor presentations, company websit es, and other company disclosures. Given the developing and innovative nature of data models, methodologies and assumptions and the inherent uncertainty in predicting forward - looking events, it cannot be guaranteed that the sustainable investing data is always accurate or correct or that the sustainable investing data will satisfy the aims or requirements of any specific client or investor. Furthermore, there may be data that cannot be sourced due to the lack of availability of data sources. For certain m arkets and types of issuers , companies or securities there may be significant limitations in the amount of sustainable investing data that is available or no sustainable investing data may be available such that no screening is performed. In certain situations where screening data is not available for an issuer, an investee company or a security, the screen provider may, as a proxy, use data relating to a different entity to the issuer or the investee co mpany, which presents a risk this data may not accurat ely reflect the sustainability or other characteristics of the issuer or the investee company. In certain situations, even where screening data is available it may not be used as part of the screen provider’s screening process. It is not expected that such limitations would affect how the environmental and social characteristics promoted by the Fund are met.
J. Due diligence
The Investment Manager, on behalf of the Fund, will invest actively using a proprietary active investment strategy which applies a fundamentally driven and bottom - up research process to identify shares considered to be trading at a discount to the assessed intrinsic value of the company. This
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Information Classification: General
opportunity set is used to construct a balanced global portfolio of 30 - 40 securities which the Investment Manager believes has the potential to provide excess returns. In selecting investments, the Investment Manager will not have any specific geographic o r sector focus. The Investment Manager will use an active investment strategy which uses a fundamentally driven and bottom - up research process to identify companies with a dislocation between the intrinsic value of the company and the price of its equity s ecurity. This will involve in - depth company and industry research by experienced sector analysts within the Investment Manager which will be applied to evaluate the future cashflow generation of a business and hence determine its intrinsic value. Areas tha t are typically researched include, inter alia, the overall industry structure, competitive dynamics and growth levels, the company’s competitive position, moat (a company’s ability to maintain a competitive edge over its competitors) and growth prospects, management’s strategy and experience, governance and the financial resilience of the business. The Investment Manager seeks to exploit valuation anomalies in the belief that in the long term share prices should ultimately reflect a company's intrinsic va lue and therefore provide excess returns. This research process integrates a review of companies’ ESG ratings and other ESG data metrics and as such the Investment Manager integrates Sustainability Risks into the investment process of the Fund
As the Fund is actively managed and seeks to outperform the Index, its holdings will differ from the Index. Non - index securities may be held in the portfolios. The Fund’s weighting to securities will be usually set without taking into account the weightings of securities in the Index. The Fund’s return will typically differ from and may under - perform, the return of the Index.
K . Engagement policies
Is engagement part of the environmental or social investment strategy?
☐ Yes
☒ No
While engagement policies are not directly embedded into the Fund’s investment strategy, proxy voting and engagement activities in respect of securities held by the Fund are conducted pursuant to the terms of the Sustainability Stewardship Service Proxy Voting and Engagement Policy (the “ Sustainability Policy ”). The Sustainability Policy focuses on risks and opportunities that may impact long - term value creation, with a focus on sustainability priorities such as climate change, nature, human rights and div ersity.
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Information Classification: General
L. Reference benchmark
Has a reference benchmark been designated for the purpose of attaining these characteristics promoted by the Fund?
☐ Yes ☒ No
The MSCI World High Dividend Yield Index is a trademark of MSCI Inc .
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