The Fund utilises a negative screening process which seeks to avoid investment in companies that derive materialrevenues from direct business involvement in activities that are unnecessarily harmful to people, animals or theenvironment.

In Pengana’s opinion, these activities are: 

Adult content 

Alcohol  Fossil fuels (GICS 101020) 

Gambling 

Genetically modified organisms (agriculture)

Human rights abuses and exploitation

Mining (GICS 151040)

Non-medical, non-regulatory animal testing 

Nuclear Power Supplier

Palm Oil production 

Securities from issuers on UN sanctions list

Severe Impact on Biodiversity

Tobacco 

Weapons

Material revenues are generally considered to be over 5% derived from production of, or 15% in aggregate derivedfrom, the production, distribution and retail of the screened product / service.

Revenue data is generally as reportedby each company in its audited financial statements. For further information please refer to the Fund’s Product Guideand to the Fund’s Responsible and ESG Investment Policy in the “Responsible Investment” tab athttps://pengana.com/our-funds/axiom-international-fund/#reports-and-resources_ 

Pengana’s Responsible Investment Policy is implemented by Axiom as the investment manager with oversight by Pengana. TheResponsible Investment Policy states the permissible extent of an investee company’s business involvement in screened activities, asdetermined by the proportion of revenues derived from that activity. Revenue data is generally as reported by each company in itsaudited financial statements. Any company that does not meet the requirements of the ethical screen is removed from the investableuniverse. For further information please refer to the Fund’s Responsible and ESG Investment Policy in the “Responsible Investment”tab at https://pengana.com/our-funds/axiom-international-fund/#reports-and-resources.

Axiom believes that ESG factors are material to achieving investment outperformance and managing investment risk. Therefore, Axiomhas integrated ESG issues into its dynamic growth investment process since Axiom’s inception in 1998. Axiom believes that significantinvestment opportunities arise when companies improve their ESG characteristics. To advance favourable outcomes, the investmentteam incorporates ESG considerations into regular engagement with company managements Axiom evaluates progress on an ongoingbasis and incorporates those developments into a proprietary risk and return rating, which influences the position sizing and proxyvoting.

Axiom is a signatory to the Principles for Responsible Investing (PRI) and has a dedicated ESG leadership committee, comprised ofsenior executives from different functional areas of the firm, that works across the organization to advance ESG policies and practices.

The Pengana Axiom International Fund invests in companies that are dynamically growing and changing for the better, more rapidly than generally expected and where the positive changes are not yet reflected in expectations or valuation. The Global Equity Strategy seeks dynamic growth by concentrating its investments in global developed markets, and may also invest in companies located in emerging markets. The investment manager is Axiom Investors, a Connecticut-based global equity fund manager formed in 1998 with over US$17billion in assets under management.

Axiom believes that ESG factors are material to achieving investment outperformance and managing investment risk. Therefore, it has integrated ESG into its dynamic growth investment process since its inception in 1998. It believes that significant investment opportunities arise when companies improve their ESG characteristics. To advance favourable outcomes, the investment team incorporates ESG considerations into the regular engagement with company management.

Axiom evaluates progress on an ongoing basis and incorporates those developments into the proprietary risk and return rating, which influences the position sizing and proxy voting. Axiom is a signatory to the Principles for Responsible Investing (PRI) and has a dedicated ESG leadership committee, composed of senior executives from every functional area of the firm, that works across the organization to ensure that everyone is advancing the ESG policies and practices.

The Fund’s ethical investment policy is implemented by Axiom with oversight from Pengana. The ethical policy states the permissible extent of an investee company’s material business involvement* in screened activities.  Any company that does not meet the requirements of the screen is removed from the investable universe.