The Fund incorporates an environmental, social and governance (ESG) strategy involving integration of Harbour’s proprietary Corporate Behaviour Survey and external provider scores into investment decision making, company engagement, voting and zero tolerance exclusions.Note: the above wording is intended to be implemented in the product PDS during the next update consistent with other products that also use this RI strategy.

As part of our active ownership process Harbour recognises there are many factors that influence our analysis, and that environmental, social and governance (ESG) considerations have grown in significance as potential value drivers.We believe that ESG factors can be a useful barometer of the quality of a company; Companies who manage ESG issues well are generally more likely to create long term shareholder value, with a reduced risk profile, compared with those companies who do not. Consequently, Harbour has integrated ESG factors directly into portfolio analysis. ESG factors are assessed in conjunction with existing comprehensive financial analysis. Our primary ESG tool is our proprietary Corporate Behaviour Survey, which we augment with external ESG specialists and broker research.Before consideration of companies in our integration approach, we have set a baseline standard of responsible behaviour based on business activity. Subsequently, the fund does not invest in companies that to our knowledge derive any revenue from:- The manufacture of tobacco- The manufacture or testing of nuclear explosive devices (NEDs)- The manufacture or sale of cluster munitions- The manufacture or sale of anti-personnel mines- The manufacture or sale of recreational cannabis- The production of pornography- The manufacture or sale of civilian automatic and semi-automatic firearms, magazines or parts