The Fund applies exclusions and negative screening in its investment process and will exclude other companies that the manager identifies unacceptable ESG risks. The Fund does not invest in companies that derive any revenue from the production of tobacco products, e-cigarettes, alcohol products; production of pornographic material, broadcasting and/or distribution of pornographic material; production and/or distribution of controversial and/or conventional weapons and armaments; exploration or mining/production of oil, gas, oil sands and coal, or distribution of the same; old forest logging and the production of non-RSPO palm tree oil; or uranium extraction or refinement. The Fund does not invest in companies that derive more than 10% of their revenues from the production of key components for tobacco production or distribution of tobacco products (e.g. through supermarkets); distribution or retailing of alcohol products; live exports, use animal testing beyond regulatory requirements, or practices that cause unnecessary harm to animals, or payday lenders or distribution of payday lending products; nor does not invest in companies that derive more than 5% of their revenues from the provision of gambling services or manufacturing gaming machines or software. It also does not invest in companies that are involved in human rights breaches that are reflected in the manager's research process.

Incorporating ESG factors into the investment process depends on the company and industry in question. The Fund Manager employs several methods of integrating ESG into its investment process, these include ESG risk identification, the use of its internal framework and third-party data providers to identify ESG risks. Where relevant, these are incorporated into the investment case, and company engagement, which is a core part of the manager's investment process, and is also used to investigate ESG risks, and communicate expectations related to ESG risks and disclosure to management and the board.

The Fund Manager's ESG risk assessment seeks to identify the most material ESG risks for each company it researches. These might include Environmental factors, such as climate change, carbon emission, water management, biodiversity, raw materials sourcing, and green products; social factors, such as labour management, modern slavery, diversity and inclusion, product safety and quality, customer privacy; and governance factors referring to corporate governance, ethics and corruption, board composition and effectiveness, remuneration, leadership and financial transparency.

The Manager seeks companies that meet its minimum ESG criteria, and where possible are positively contributing to the United Nations Sustainable Development Goals ('UN SDGs').