Summary

The impact objective of the Common Good Fund (hereinafter: the ‘Fund’) is to generate measurable positive social and environmental outcomes by directing capital to solutions that uphold human dignity, and care for our common home, defined as  planet Earth;  a shared, finite, and interconnected habitat for all humanity and living creatures. To provide structure to this ambition, we are guided by the principles of Mensuram Bonam ('For the Measurement of the Good'). Rooted in the tradition of Catholic Social Teaching, this framework provides an ethical basis for translating our values into investment criteria.

To uphold human dignity, we will invest in the following social Impact Themes:

1. Financial Inclusion – Expanding access to affordable, high-quality financial services for underserved individuals and MSMEs, improving financial health, resilience and economic opportunity.
2. Access to Education – Increasing availability and quality of education and digital learning tools, supporting improved learning outcomes, affordability, and employability.
3. Access to Healthcare – Improving access to affordable, quality healthcare products and services, particularly for low-income populations, addressing healthcare inequality and improving well-being.
4. Affordable, Accessible and Quality Housing - Focusing on the acquisition, development, preservation and rehabilitation of housing in underserved residential markets with unmet needs. Our focus includes housing for low- and moderate-income households, essential and key workers, families, seniors and people with disabilities.

To care for our common home, we will focus on investing in the following environmental Impact Theme:

5. Climate – Supporting the transition to a low-carbon, climate-resilient economy through clean energy generation, energy efficiency, and decarbonisation solutions.

The Fund pursues a global multi-manager, multi-asset impact investing strategy aimed at generating attractive risk-adjusted financial returns while delivering positive, measurable social and environmental outcomes. The Fund invests in underlying private funds, with a primary focus on funds managed by managers that engage in climate-focused and/or socially responsible investing (“Portfolio Funds”). This objective is pursued with the aim of upholding human dignity and caring for our common home, by investing in the five clearly defined impact themes as mentioned above.

The Fund invests at least 80% of its net asset value in sustainable investments, which will be split between sustainable investments with an environmental objective (minimum 25%) and sustainable investments with a social objective (minimum 25%). The Fund may, from time to time invest up to a maximum of 20% of its assets in direct investments that do not qualify as sustainable investments. These investments consist of cash and money market instruments held for liquidity and/or rebalancing purposes, and derivatives for hedging and efficient portfolio management purposes.

As a fund of funds, the Fund invests in investments that are managed by other investment managers. The Fund assesses DNSH by considering the principal adverse impact (PAI) indicators set out in the SFDR. Where the underlying fund does not report certain PAIs, Anthos uses the best available information, including external data, estimates and qualitative assessment, to evaluate whether the investment may cause significant harm.

Anthos also identifies and monitors the potential adverse impacts of the investment funds this financial product invests in by assessing the ESG investment practices implemented by the external investment managers of these investment funds, and more specifically obtaining information from them on the potential adverse impacts they make through their investment fund’s underlying investments. Pre-investment, Anthos assesses these external investment managers on a wide scope of criteria (Negative impacts of the portfolio to the world, exclusions applied to the investment funds, Diversity, Equity & Inclusion, climate change) using the Anthos ESG Scorecard. This financial product only invests in investment funds that score either as ‘Professional’ or ‘Leader’ on the Anthos ESG Scorecard. This financial product implements Anthos' exclusion list by communicating the exclusions criteria to its external managers during the pre-investment phase.

The Fund integrates the OECD Guidelines for Multinational Enterprises (MNEs) and the UN Guiding Principles on Business and Human Rights (UNGPs) through a commitment to human rights, responsible investing, and sustainability.

As a fund of fund manager, Anthos relies on its external investment managers for engagement in connection to the investee companies. However, Anthos believes it also needs to address active ownership through additional engagement activities, either via a service provider or, where possible, directly. This enhances investor stewardship and the pursuit of responsible investment.

Although a benchmark is used for comparing its financial performance, this financial product does not use a specific benchmark to determine whether it is aligned with its sustainable investment objectives. This financial product attains its sustainable investment objectives through its investment guidelines, which are based on its investment strategy.

 

1. No significant harm to the sustainable investment objective

As a fund of funds, the Fund invests in investments that are managed by other investment managers. Anthos therefore requires that the investment managers of these external investment funds demonstrate to Anthos that the underlying investments do not significantly harm the sustainable investment objectives of the respective external investment funds.

Such demonstration has to be done by considering all of the principal adverse impact indicators that are stated in Annex I of the SFDR regulatory technical standards. For external investment funds that have an article 9 SFDR financial product classification, the Fund will also consider the article 9 SFDR pre-contractual and periodical disclosures of each such external investment fund.

The Fund assesses DNSH by considering the principal adverse impact (PAI) indicators set out in the SFDR. Where the underlying fund does not report certain PAIs, Anthos uses the best available information, including external data, estimates and qualitative assessment, to evaluate whether the investment may cause significant harm.

The Fund monitors DNSH on an ongoing basis and engages with underlying managers to improve data availability over time and to reduce PAIs where these exceed the defined thresholds.

Anthos also identifies and monitors the potential adverse impacts of the investment funds this financial product invests in by assessing the ESG investment practices implemented by the external investment managers of these investment funds, and more specifically obtaining information from them on the potential adverse impacts they make through their investment fund’s underlying investments. Pre-investment, Anthos assesses these external investment managers on a wide scope of criteria (Negative impacts of the portfolio to the world, exclusions applied to the investment funds, Diversity, Equity & Inclusion, climate change) using the Anthos ESG Scorecard. This financial product only invests in investment funds that score either as ‘Professional’ or ‘Leader’ on the Anthos ESG Scorecard.

This financial product implements Anthos' exclusion list by communicating the exclusions criteria to its external managers during the pre-investment phase. This exclusion list is included in the side letter upon investment. Businesses that should be eliminated include tobacco, gambling, controversial weapons, adult content when they are responsible for more than 5% of revenues. The external investment funds usually already have an exclusion list aligned with Anthos’ exclusion list or aligned with the IFC exclusion list (which is stricter than Anthos’ exclusion list).

The Fund integrates the OECD Guidelines for Multinational Enterprises (MNEs) and the UN Guiding Principles on Business and Human Rights (UNGPs) through a commitment to human rights, responsible investing, and sustainability. The impact team adopts risk-based due diligence across its investment process, ensuring that ESG factors are embedded next to an impact assessment to address social, environmental, and governance risks while aligning portfolios with sustainable development goals (“SDG”). An exclusion list is a starting point to determine where there should not be an exposure from values and sustainability perspective. The ESG Scorecard, which is at the core of the due diligence process, includes all the relevant questions for the assessment of the external manager's capacity to identify and manage potential and actual risks and impacts. The same Scorecard questionnaire is used throughout the investment period to engage and work towards improvement.

 

2. Sustainable investment objective of the financial product

The impact objective of the Common Good Fund (“Fund”) is to generate measurable positive social and environmental outcomes by directing capital to solutions that uphold human dignity, and care for our common home, defined as  planet Earth;  a shared, finite, and interconnected habitat for all humanity and living creatures.

To provide structure to this ambition, we are guided by the principles of Mensuram Bonam ('For the Measurement of the Good'). Rooted in the tradition of Catholic Social Teaching, this framework provides an ethical basis for translating our values into investment criteria. This approach affirms that our portfolio seeks to not merely avoid harm, but to support human dignity and care for our common home. By integrating the principles of Mensuram Bonam, we move beyond standard ESG integration toward a deeper, values-based integration.

We translate the principles of Mensuram Bonam into investable impact themes and align with the Sustainable Development Goals (“SDGs”) to make sure that we are investing to address real world needs.

The Fund’s investment objective is to invest in underlying private funds, with a primary focus on funds managed by managers that engage in climate-focused and/or socially responsible investing (“Portfolio Funds”). This objective is pursued with the aim of upholding human dignity and caring for our common home.

The Fund will invest in assets that contribute to a more sustainable society and environment via investing in non-listed instruments, ensuring that every investment delivers impact while integrating a carefully balanced risk and return.

Inspired by the principles of Mensuram Bonam we believe that the Fund, by actively selecting for impact investments, responds to the ‘call to enhance’, by actively engaging with our underlying managers, responds to the ‘call to engage’ and by actively investing in areas which align with our values and excluding those that do not, we respond to the ‘call to exclude’.

To uphold human dignity, we will invest in the following social Impact Themes:

1. Financial Inclusion – Expanding access to affordable, high-quality financial services for underserved individuals and MSMEs, improving financial health, resilience and economic opportunity.
2. Access to Education – Increasing availability and quality of education and digital learning tools, supporting improved learning outcomes, affordability, and employability.
3. Access to Healthcare – Improving access to affordable, quality healthcare products and services, particularly for low-income populations, addressing healthcare inequality and improving well-being.
4. Affordable, Accessible and Quality Housing - Focusing on the acquisition, development, preservation and rehabilitation of housing in underserved residential markets with unmet needs. Our focus includes housing for low- and moderate-income households, essential and key workers, families, seniors and people with disabilities.

To care for our common home, we will focus on investing in the following environmental Impact Theme:

5. Climate – Supporting the transition to a low-carbon, climate-resilient economy through clean energy generation, energy efficiency, and decarbonisation solutions.

The Fund operationalises its sustainable investment objective through Theories of Change (“ToC”) for each of the five impact themes that structure how capital allocation leads to positive, measurable outcomes. Each ToC identifies: (1) the inputs provided by the Fund (capital, expertise, engagement), (2) the activities of underlying fund managers, (3) the outputs measured through indicators, and (4) the longer-term outcomes aligned with relevant SDGs.

 

3. Investment strategy

The Fund pursues a global multi-manager, multi-asset impact investing strategy aimed at generating attractive risk-adjusted financial returns while delivering positive, measurable social and environmental outcomes. The Fund invests in underlying private funds, with a primary focus on funds managed by managers that engage in climate-focused and/or socially responsible investing (“Portfolio Funds”). This objective is pursued with the aim of upholding human dignity and caring for our common home, by investing in the five clearly defined impact themes as mentioned above.

These five impact themes translate the principles of Mensuram Bonam into investable themes and are aligned with the SDGs, ensuring that investments address real-world needs. They are operationalised through a robust Theory of Change framework, which structures how capital allocation leads to measurable impact. For each theme, the Fund defines:

• the inputs provided to investment funds;
• the activities of fund managers;
• the output indicators monitored annually; and
• the long-term outcomes aligned with the SDGs.

This ensures that every allocation contributes to a clearly defined, measurable and evidence-based impact pathway.

The following binding elements apply to attain this financial product’s sustainable investment objective.

All of the Fund’s assets invested in Portfolio Funds qualify as sustainable investments (100%). Of these investments, at least 80% is allocated to Portfolio Funds with a sustainable impact objective aligned with the five impact themes defined by the Fund.

Impact Theme Alignment

Investing at least 80% of the capital to one or more of the five defined impact themes:

1. Financial Inclusion
2. Education
3. Healthcare
4. Affordable, Accessible and Quality Housing
5. Climate

ESG Score

• All (100%) of the external funds must be managed by Professional or Leader ESG-rated managers, according to the Fund’s ESG Scorecard (“ESG Score”).

Impact Score

• All (100%) of the external funds should have a minimum Impact Score indicating a baseline of credibilty and maturity, according to the Fund’s Impact Scorecard.
• All (100%) of the external investment funds eligible for consideration for the Fund should have an Impact label of “Benefit stakeholders (B)” or “Contribute to solutions (C)”.

Exclusion Guidelines Adherence

All investments are subject to the Fund’s Exclusion Guidelines (including the PAB-exclusions), which form an integral part of the investment strategy and are applied throughout the investment lifecycle. The exclusions are applied at the level of investee companies and, in the case of investments through underlying funds, are embedded through manager selection, contractual commitments and ongoing monitoring.

Given the Fund’s fund of funds structure, the application of these exclusions is based on  due diligence using available data and information provided by external managers. The Fund assesses, prior to investment and on an ongoing basis, whether underlying managers have the policies, processes and capacity to implement the Exclusion Guidelines in line with market practice for private markets.

 

Source	Category	Activity / practice excluded	Tolerance
Regulatory — ESMA minimum exclusions (Art. 12(1)(a)–(g), CDR 2020/1818)
ESMA regulatory	Controversial weapons	Companies involved in any activities related to controversial weapons	0%
ESMA regulatory	Tobacco cultivation and production	Companies involved in the cultivation and production of tobacco	0%
ESMA regulatory	UN Global Compact / OECD Guidelines violations	Companies assessed to be in violation of UNGC and/or OECD Guidelines for Multinational Enterprises	0%
ESMA regulatory	Coal and lignite	Exploration, mining, extraction, distribution, or refining of hard coal and lignite	<=1% revenue
ESMA regulatory	Oil fuels	Exploration, extraction, distribution, or refining of oil fuels	<=10% revenue
ESMA regulatory	Gaseous fuels	Exploration, extraction, manufacturing, or distribution of gaseous fuels	<=50% revenue
ESMA regulatory	High-intensity power generation	Electricity generation with GHG intensity exceeding 100 g CO2/kWh	<=50% revenue
2.1 Intrinsic dignity of human life (life ethics)
Fund exclusion guidelines	Abortion	Development, production or distribution of abortifacients, or operation of abortion clinics	0%
Fund exclusion guidelines	Treatment and use of embryos / stem cells	Destruction or cryopreservation of human embryos; human embryonic/fetal stem cell research involving destruction of embryos or abortion of fetuses; research utilising multiple lines of human embryonic/fetal stem cells; manufacture of equipment used exclusively for such research	0%
Fund exclusion guidelines	Reproductive medicine	Use of heterologous IVF techniques (sperm/egg donation/surrogacy) or IVF involving surplus embryos; IVF for conception assistance or research	0%
Fund exclusion guidelines	Contraceptives	Development and manufacture of contraceptives	<=10% revenue
Fund exclusion guidelines	For-profit prisons	Operation of for-profit prisons	0%
Fund exclusion guidelines	Euthanasia and assisted suicide	Provision or mediation of active euthanasia or assisted suicide; manufacture of materials produced/marketed solely for euthanasia or assisted suicide; entities that facilitate euthanasia or assisted suicide (indirect)	0%
Fund exclusion guidelines	Capital punishment	Companies producing poisons manufactured exclusively for capital punishment (pharmaceutical, medical supplies, equipment); entities that facilitate capital punishment (indirect)	0%
2.2 Patterns leading to addiction and abuse
Fund exclusion guidelines	Alcohol	Production, sale, or distribution of alcohol/liquor products, unless ancillary to the primary business and not targeting vulnerable populations	<=10% revenue
Fund exclusion guidelines	Tobacco (incl. vaping and e-cigarettes)	Production of tobacco products; ownership of tobacco manufacturers; distribution or retail of tobacco products	0% production / <=5% distribution / <=10% ownership
Fund exclusion guidelines	Gambling	Direct ownership/operation of gambling establishments; manufacture of specialised gambling equipment; products/services used exclusively for gambling. Suppliers where activity <10% revenue are investable only with effective social harm safeguards — excluded without safeguards regardless of revenue share	<=5% revenue (direct)
Fund exclusion guidelines	Cannabis and cannabis-derived products	Production or distribution of cannabis or cannabis paraphernalia	0%
Fund exclusion guidelines	Adult entertainment and pornography	Manufacture of pornographic products and services or involvement in prostitution; distribution of pornography or adult entertainment materials	0%
Fund exclusion guidelines	Violent media	Production of violent media content rated for mature audiences (ESRB Mature/Adults Only; MPA R/NC-17; TV-MA); distribution of such content	0% production / <=10% distribution
2.3 Armaments, human rights and global justice
Fund exclusion guidelines	Controversial and indiscriminate weapons	Development, production, stockpiling, distribution, or sale of weapons prohibited under international humanitarian law: nuclear (incl. first-strike), biological/chemical weapons, cluster munitions, anti-personnel mines, depleted uranium weapons, white phosphorous weapons, WMD	0%
Fund exclusion guidelines	Conventional weapons and related systems	Manufacture and distribution of armaments incl. assault weapons to civilians or military/law enforcement; key components of small arms and military weapon systems; tailor-made components or support products/services; dual-use products	<=5% revenue
Fund exclusion guidelines	Human rights — international standards	Large-scale, serious, persistent and systemic restrictions on internationally recognised human rights (UDHR); gross violations of ILO core principles (freedom of association, collective bargaining, forced labour, child labour, discrimination); breach of ILO minimum standards (safety, health, pay, working hours, education and training)	0%
Fund exclusion guidelines	Land rights	Large-scale land acquisition or land grabbing in vulnerable regions where free, prior and informed consent (FPIC) of affected communities is absent	0%
Fund exclusion guidelines	Water	Monopolistic or exploitative control of essential water resources (incl. drinking water) where practices undermine access, affordability, or community rights	0%
Fund exclusion guidelines	Food commodity speculation	Large-scale trading in food commodity derivatives primarily to make speculative gains	0%
Fund exclusion guidelines	Hazardous waste exports	Waste exports in breach of the 1989 Basel Convention on transboundary movements of hazardous wastes and their disposal	0%
Fund exclusion guidelines	Breast-milk substitutes / pharma marketing	Breaches of international agreements on marketing of breast-milk substitutes or IFPMA code of practice for marketing of pharmaceutical products	0%
Fund exclusion guidelines	Financial crime	Gross violations of Financial Action Task Force (FATF) standards	0%
Fund exclusion guidelines	Controversial business practices	Evidence of corruption, data falsification, false accounting, or fraud	0%
2.4 Environmental protection and stewardship of creation
Fund exclusion guidelines	Coal and lignite (product-level)	Exploration, mining, extraction, distribution, or refining of hard coal and lignite	<=1% revenue
Fund exclusion guidelines	Oil sands extraction	Extraction from oil sands	<=10% revenue
Fund exclusion guidelines	Arctic oil and gas	Oil and gas exploration in the Arctic	<=5% revenue
Fund exclusion guidelines	Nuclear power	Companies operating nuclear power plants; products and services for/from nuclear power plants	0% (operations) / <=10% revenue (products/services)
2.5 Biodiversity, biosafety and animal welfare
Fund exclusion guidelines	Ecosystem degradation	Activities that materially degrade ecosystems or reduce species diversity without applying recognised best-practice measures to assess, manage and remediate impacts	0%
Fund exclusion guidelines	EU-prohibited chemical substances	Manufacture of and trade in chemical substances prohibited in the EU	<=5% revenue
Fund exclusion guidelines	Environmental laws / project harm	Gross disregard of environmental laws or generally recognised minimum environmental standards; operation of projects (pipelines, mines, dams) with particularly harmful effect on ecosystems	0%
Fund exclusion guidelines	Ecosystem-harming project financing	Financing of large-scale projects (pipelines, mines, dams) with particularly harmful effect on regional ecosystems	<=20% of financing
Fund exclusion guidelines	GMOs	Development or commercialisation of Genetically Modified Organisms where such activity raises material ethical, environmental, or biosafety concerns	0%
Fund exclusion guidelines	Hazardous biocides	Manufacture or trade of biocides classified as 'extremely or highly hazardous' by the World Health Organization	0%
Fund exclusion guidelines	Water resource depletion	Activities that materially deplete or degrade water resources incl. drinking water without a credible approach to avoiding, minimising, and mitigating impacts	0%
Fund exclusion guidelines	Factory farming and fur	Factory farming or mass transportation of livestock; fur farming (incl. breeding establishments)	0%
Fund exclusion guidelines	Animal testing	Breach of animal welfare regulations related to animal testing; manufacture of products for which tests not required by law have been carried out on animals	0%

 

Further details, definitions, scope and revenue tolerance thresholds are set out in the Fund’s Exclusion Guidelines, which are available at Exclusion guidelines.

 

Underlying Fund Reporting requirements

• All (100%) underlying external managers must comply with the Fund’s reporting requirements to ascertain their sustainable investment objective.

 

4. Proportion of investments

 

#1 Sustainable:

The Fund invests at least 80% of its net asset value in sustainable investments, which will be split between sustainable investments with an environmental objective (minimum 25%) and sustainable investments with a social objective (minimum 25%), with the remaining 30% floating between the two as either environmentally or socially sustainable as to allow for flexibility for portfolio constuction carefully balancing risk and return as fitting in the strategy of the Fund.

 

#2 Not Sustainable:

The Fund may, from time to time invest up to a maximum of 20% of its assets in direct investments that do not qualify as sustainable investments. These investments consist of cash and money market instruments held for liquidity and/or rebalancing purposes, and derivatives for hedging and efficient portfolio management purposes.

 

5. Monitoring of the sustainable investment objective

This financial product does not invest directly in investee companies, but indirectly, through its direct investments in investment funds. Before investing in a new investment fund for this financial product, Anthos performs an assessment on the policies of the investment manager of that investment fund, including whether material ESG factors – such as good corporate governance practices at investee companies – are considered in the investment process. Such assessment of the investment manager is repeated by Anthos on a periodic basis (mostly yearly). Furthermore, this financial product is screened on a periodic basis (mostly yearly) to determine whether an investee company is violating or at risk of violating, one or more of the UN Global Compact Principles and related international norms and standards.

In addition to this, Anthos engages on a regular basis with the external investment managers on the components of the ESG Scorecard to:

1. ensure the ESG rating correctly reflects the responsible investments practices of the investment manager; and
2. signal the importance of responsible investing, highlight Anthos' expectations about key ESG characteristics (for example, Climate Change, DEI and Human rights) and monitor the progress made against Anthos' expectations.
    

6. Methodologies

Anthos uses the sustainability indicators set out below to measure the attainment of the sustainable investment objectives of the investments in the Fund.

 

Sustainability indicators applied at Fund level

To measure the attainment of its sustainable investment objective, the Fund measures sustainability indicators (KPIs) across healthcare, education, climate, financial inclusion and affordable, accessible and quality housing.  KPIs per Impact theme are listed below directly above the corresponding Theory of Change.

 

The Fund measures the percentage of assets under management allocated to each of the above 5 impact themes. As the Fund is structured as a private asset fund-of-funds, the KPIs are measured at the Fund level. These KPIs represent measurable outputs that demonstrate progress toward the intended outcomes defined in each ToC.

 

KPIs specific to each of the 5 themes:

• Healthcare (SDG 3)
  • # of people provided better access to healthcare
  • % positive change in healthcare related indicators

 

• Education (SDG 4, 8, 10)
  • # people provided access to educational products or services

 

• Climate (SDG 7, 9, 13)
  • Volume of green products/services provided and/or sold
  • # of reduced/avoided GHG emissions

 

• Financial Inclusion (SDG 1, 8, 10)
  • # people provided better access to finance
  • # of SMEs/MSMEs funded/enabled

 

• Affordable, Accessible and Quality Housing (SDG 11)
  • # of affordable housing units created/rented/preserved
  • # of people provided better access to affordable housing

 

In addition to the KPIs listed for each of the five impact themes, the Fund may select additional KPIs where these contribute to providing a more accurate, relevant, or robust reflection of the impact achieved within a specific theme. The selection of such additional KPIs will follow the structured process set out below:

1. First, an assessment will be made whether the existing KPIs sufficiently capture the material outcomes associated with the underlying investments. If not, supplementary KPIs will be identified using recognised industry frameworks such as IRIS+, the SDGs, and other domain specific standards to ensure consistency, comparability, and methodological soundness.
2. Second, the applicability and measurability of the proposed KPI will be evaluated during due diligence and ongoing monitoring. Any new KPI adopted will be documented and integrated into the reporting framework of the relevant manager. Reporting on additional KPIs will be included in the Fund’s periodic reporting, ensuring transparency regarding the rationale for their selection and how they contribute to assessing progress toward the Fund’s sustainable investment objective.

Sustainability indicators applied at external fund manager level

The Fund uses the following sustainability indicators at the external fund manager level to assess how the Fund’s sustainable investment objectives are met, namely, investing in external impact funds and ensuring that their impact objectives contribute to the Fund’s impact objective.

For a Portfolio Fund to be eligible for consideration as an impact investment, the external fund manager must first meet the Fund’s ESG threshold, qualifying as either 'a Professional' or 'a Leader'. This initial screening provides confidence that the external manager has the ESG maturity and operational capacity necessary to deliver on the Portfolio Fund’s stated impact objectives.

This results in the following sustainability indicator:

1. ESG-score:

• % of external funds managed by Professional or Leader ESG-rated managers, according to the Fund’s Responsible Investing Scorecard (“ESG Score”).

2. Reporting requirements:

• % Adherence to the reporting requirements by the underlying external manager to ascertain their sustainable investment objective.

Sustainability indicators applied at Portfolio Fund level

Once a prospective Portfolio Fund has passed this ESG threshold, the external fund manager and Portfolio Fund are assessed on impact credentials and approach.  First and foremost, in the initial due diligence stage, the impact strategy or objective of each prospective Portfolio Fund is carefully assessed, focusing on how the products and services, resulting from their investments, contribute to positive social or environmental outcomes. Investments are made only in Portfolio Funds which have a clear and credible impact objective, and where 80% of more of their AUM is invested (or expected to be invested) in impact.

Once the Portfolio Fund has passed the initial due diligence screen and has progressed to full due diligence, a proprietary Impact Questionnaire is used which assesses each fund manager and their fund on 4 key areas. These areas are:

1. Impact Strategy;
2. Impact Measurement and Management (IMM);
3. Impact Governance; and
4. Impact Reporting.

Based on the combined scores, an Impact Score reflecting the Portfolio Fund’s credibility and maturity will be assigned, which must be met prior to investment. Improvements to the underlying Portfolio Fund’s scores are then pursued, where needed, through engagement carried out during the monitoring process, so that even higher levels of credibility and maturity can be achieved.

 

This results in the following sustainability indicators:

1. Impact score:

• % of external funds meeting minimum Impact Score indicating a baseline of credibilty and maturity, according to the Fund’s Impact Scorecard.

2. Impact label:

• % of external investment funds classified as having an Impact label of “Benefit stakeholders (B)” or “Contribute to solutions (C)”.

3. Exclusion Policy Adherence

• % Adherence of the underlying funds to the Fund’s Exclusion policy, including the Paris Aligned Benchmark (“PAB”) Exclusions.

 

7. Data sources and processing

Anthos assesses all investment funds that are considered for this financial product on responsible investment practices and key ESG characteristics prior to investing, using its proprietary tools (ESG Scorecard), The ESG rating shows the quality of the integration of environmental, social and governance assessments in the investment process at the investment manager.

The ESG rating is the result of an internal assessment performed by the Anthos portfolio managers and their analysts, based on the relevant information shared by the external investment managers themselves during the RFP phase or during engagement conversations that take place at least on a yearly basis.

 

8. Limitations to methodologies and data

Assessing the information shared by the external investment managers may be influenced by the amount of knowledge of the Anthos staff performing the assessment on ESG practices, ESG topics, market standards, etcetera. Anthos mitigates this limitation by providing regular training to its staff, either on processes or specific topics (for example climate training and human rights workshops). The Anthos ESG Scorecard are accompanied of a scoring guide which indicates which kind of requirements lead to specific ratings/labels/scores.

The assessments are also reviewed by the Anthos Responsible Investments Team on an as-needed basis and the tools are continuously improved to keep up with market standards.

Anthos aims to incorporate outcomes in its assessment, as external ESG and Impact data becomes more reliable and methodologies more robust.

 

9. Due diligence

As part of the due diligence process the external investment manager as well as the investment fund are investigated by the portfolio manager. Therefore, the external investment manager has to provide the information necessary for Anthos to be able to perform the sustainability assessment. Once the information is received, Anthos will assess the information resulting in an ESG score ‘Laggard’, ‘Novice’, ‘Professional’ or ‘Leader’.

Anthos assesses the governance structure and resources of the external manager to manage environmental, social and governance issues and integrate in the investment process. The assessment contributes to the final rating of the managers on ESG (Laggard-Leader) which helps the portfolio managers make a decision.

During the due diligence, the first assessment is done by the portfolio manager, together with their analysts. The assessments are also reviewed by the Anthos Responsible Investments Team on an as-needed basis and the tools are continuously improved to keep up with market standards.

 

10. Engagement policies

As a fund of fund manager, Anthos invests in segregated mandates and investment funds managed by external investment managers, and it relies on these external investment managers for engagement and voting in connection to the investee companies. However, Anthos believes it also needs to address active ownership through additional engagement activities, either via a service provider or, where possible, directly. This enhances investor stewardship and the pursuit of responsible investment.

Anthos has high expectations of the external investment managers selected for this financial product and incorporates ESG considerations into the entire external investment manager due diligence and relationship lifecycle. Anthos expects the selected external investment managers to be signatories of the Principles for Responsible Investment (PRI) and to support the Principles of the European Fund and Asset Management Association (EFAMA) Stewardship Code or a similar guidance, which clearly outlines engagement and voting good practices for direct investors.

Internally, engagement is carried out by Anthos’s portfolio managers, who assess the ESG integration capacity and quality of the external investment managers of the investment funds that this financial product invests in. Anthos also engages via an external engagement service provider that engages on behalf of Anthos' clients, even when Anthos does not appear as shareholder at the investee companies in question. In this way Anthos gives its voice to the pool of like-minded investors wanting meaningful change.

More information on Anthos' engagement process and objectives can be found in its Stewardship Policy.

 

11. Attainment of the sustainable investment objective

Although a benchmark is used for comparing its financial performance, this financial product does not use a specific benchmark to determine whether it is aligned with its sustainable investment objectives. Going forward, Anthos will keep on monitoring whether any benchmark could become relevant regarding the sustainable investment objectives of this financial product. This financial product attains its sustainable investment objectives through its investment guidelines, which are based on its investment strategy.