The Fund will not invest in companies or issuers directly involved in tobacco production (including e-cigarettes and inhalers) and controversial weapons manufacture. The Fund will also not invest in companies or issuers directly involved in activities that account for 10% or more of a company's or issuer's gross revenue, such as the production of alcohol, manufacture or provision of gaming facilities, manufacture of non-controversial weapons or armaments, manufacture or distribution of pornography, uranium mining for the purpose of nuclear power generation, extraction of thermal coal and oil sands production.

Pendal believes that analysis of ESG factors contributes to better informed investment decisions and can improve the quality and consistency of long-term value creation. It defines ESG integration as the inclusion of ESG factors within investment analysis and decision making. Where any ESG considerations may impact the financial performance of an investment, those factors are considered as part of the Manager's active investment processes, which will analyse material ESG risks and opportunities using proprietary methodology developed inhouse. Pendal typically adopts an "open architecture" approach to ESG integration, allowing for the flexibility of incorporating additional information and data as it is presented. 

Engagement with investee companies and issuers is a key part of the Manager's investment approach. It offers them the opportunity to raise concerns directly with the company or issuer, to get a clearer understanding of the actions they are taking and to advocate for change. Pendal supports the transition to a more sustainable economy and takes a pragmatic approach in its analysis and stewardship activity.

Pendal has been a signatory to the United Nations supported Principles for Responsible Investment (PRI) since 2007. In 2018 Pendal commenced public reporting aligned to the recommendations of the Task Force on Climate-related Financial Disclosures (TCFD).