WELLINGTON ALL-CHINA FOCUS EQUITY FUND
Sustainability-related disclosures
This sustainability-related disclosure includes information relating to environmental and social characteristics of the financial product, and sustainable investments, in accordance with the Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on sustainability-related disclosures in the financial services sector (SFDR) requires that firms publish information on any environmental (E) or social (S) characteristic that their products promote and on any sustainable investment objective that their products pursue. This document is intended to provide a description of these features for this Fund, together with information on the methodologies used to assess, measure and monitor them. This document should be read in conjunction with the Fund’s Prospectus (including the pre-contractual disclosure), and periodic disclosure in the annual report before investing which can be found on the following website at www.wellington.com in the Funds section
summary
The Fund promotes a social characteristic, however it does not use a reference benchmark for the purpose of attaining this, or make any sustainable investments. The Fund seeks to assess and promote the adoption of appropriate policies and practices among certain investee companies with regard to modern slavery risk management, forced labour, child labour and debt bondage (“Modern Slavery”). In order to do this, the Investment Manager applies Wellington Management Group’s Emerging Markets Modern Slavery Policy (the “EM Modern Slavery Policy”). Under the EM Modern Slavery Policy investee companies are evaluated by the Investment Manager on the basis of proprietary research and third-party research for inclusion to the Watch List (as defined below) and various levels of engagement are undertaken over a period of time until adequate remediation measures are adopted. At a minimum, all companies held in the Fund for a period of one year or longer will be subject to engagement regarding Modern Slavery risk management via an initial survey outreach. Due to the Fund’s expected turnover, some companies may be held in the Fund for less than a year and as a result may not be engaged with regard to Modern Slavery risk management. Additionally, the Investment Manager excludes companies which have been assessed to be in violation of United Nations Global Compact principles 4 (businesses should uphold the elimination of all forms of forced and compulsory labour) or 5 (businesses should uphold the effective abolition of child labour) due to known controversies regarding child labour or forced labour. A minimum of 70% of the Fund’s net assets will be aligned to the E/S characteristics of the Fund. The Fund will also apply the Exclusion Policy which excludes issuers which are involved in certain activities as described in the Investment Strategy section below. Good governance practices of investee companies are assessed using proprietary G ratings where available in accordance with its Good Governance Assessment Policy. These ratings rely on a combination of internal and/or external data inputs. The attainment of the environmental and social characteristics are monitored through internal compliance screening performed pre-trade, intra-day, and in an overnight post-trade process. The primary source of Modern Slavery data will be directly obtained from the underlying companies via an engagement survey in order to seek to obtain consistent information regarding a company’s policies and procedures. In addition, the Investment Manager will consider industry risk, country risk and reported labour controversies, as well as other sources as necessary. The EM Modern Slavery Policy engagement process can be divided into four component steps: 1. Modern Slavery engagement survey 2. Watch List inclusion 3. Enhanced engagement 4. Watch List revision, which yields watchlist removal or divestment. Some aspects of the EM Modern Slavery Policy engagement process will be managed manually. This will include the engagement process and aspects of the engagement process. As such the monitoring of these steps will be undertaken manually instead of a automated and systematic process. In some cases, investee companies may choose not to complete and return a survey or otherwise provide transparent information on their Modern Slavery risk management practices. The results of the survey are not independently verified and may be subject to revision should the investee company or the Investment Manager override the data of a previously submitted survey.
NO SUSTAINABLE INVESTMENT OBJECTIVE
This financial product promotes environmental or social characteristics, but does not have as its objective a sustainable investment