Notification of changes to the underlying funds of various Robeco funds

29 Apr 2025

We have been notified by the board of directors of Robeco Capital Growth Funds (the “Company”) of changes to the underlying funds of the Affected Mirror Funds detailed below.  These changes will take effect from 7 May 2025 (the “Effective Date”).  

• L91 Robeco Smart Energy (USD) / Z72 Robeco Smart Energy (USD)*
  • (“Affected Mirror Fund 1”)
• L96 Robeco Sustainable Water (USD) / Z74 Robeco Sustainable Water (USD)*
  • (“Affected Mirror Fund 2”)
• L97 Robeco Sustainable Healthy Living (USD) / Z73 Robeco Sustainable Healthy Living (USD)*
  • (“Affected Mirror Fund 3”)
• L98 Robeco Global Gender Equality (USD) / Z71 Robeco Global Gender Equality (USD)*
  • (“Affected Mirror Fund 4”)

 (together the “Affected Mirror Funds”) 

Background
The Company has advised that it is making a number of amendments to the prospectus of the underlying funds of the Affected Mirror Funds in order to comply with new guidelines published by the European Securities and Markets Authority (“ESMA”) regarding environmental, social and governance (“ESG”) or sustainability related terms. 

Change relating to Affected Mirror Funds 1-4 
The Company applies its Robeco Exclusion Policy criteria, at either level 1 or level 2, as part of its sustainable investment approach when selecting securities for the investment universe. The differences between level 1 and level 2 are presently detailed in the Robeco Exclusion Policy which can be found on the Company's web site.
 
The sustainability disclosures section of the prospectus of the underlying funds will be updated from the Effective Date, specifying which exclusion level applies to each individual fund. Please refer to Section 1 of the Appendix opposite for details of the updated text which will be applicable to the underlying funds of Affected Mirror Funds 1-4.

Removal of sustainable benchmark of Affected Mirror Fund 1 
From the Effective Date, the current binding element to achieve a better carbon footprint than the Custom Bloomberg Climate Transition Benchmark, will be replaced with an alternative binding element, that more closely reflects the investment theme of the underlying fund.

Changes relating to Affected Mirror Funds 1-2 
From the Effective Date, additional environmental/social characteristic, sustainability indicator and binding element will be added to the underlying funds of Affected Mirror Funds 1-2, to adhere to exclusion criteria from the Paris-aligned Benchmarks. 

Paris-aligned Benchmark exclusions broadly prohibit investments in companies involved in controversial weapons or tobacco; having violated UN Global Compact principles or OECD Guidelines for Multinational Enterprises; or deriving revenues above certain specified thresholds from coal, oil, gas or electricity generation.

Please refer to Section 2 of the Appendix opposite for details of the updated text which will be applicable to the underlying funds of Affected Mirror Funds 1-2.

Changes relating to Affected Mirror Funds 3-4
The underlying fund of Affected Mirror Funds 3-4 will be updated from the Effective Date, in order to comply with ESMA guidelines on fund names which include sustainability or ESG related terms. 

Additional environmental/social characteristic, sustainability indicator and binding elements will be added to the underlying fund of Affected Mirror Funds 3-4 from the Effective Date to adhere to exclusion criteria of the Climate Transition Benchmarks. 

Climate Transition Benchmarks incorporate specific objectives related to emission reductions and the transition to a low-carbon economy (based on the scientific evidence of the Intergovernmental Panel on Climate Change) through the selection and weighting of underlying constituents. Please refer to Section 3 of the Appendix opposite for details of the updated text which will be applicable to the underlying fund of Affected Mirror Funds 3-4.

Change relating to Affected Mirror Fund 3
In line with the ESMA guidelines, Affected Mirror Fund 3 (in both applicable regional designated variants) will be renamed from the Effective Date:. 

Updated pre-contractual disclosure documents will be made available as part of the prospectus of the underlying funds following the Effective Date.

These changes will take effect automatically and policyholders do not need to take any action. We recommend that policyholders seek the advice of their usual financial adviser before making any investment decisions.

Should you have any questions regarding these changes, please contact the Investment Marketing Team.

*Fund variant applicable to Hong Kong designated policyholders. Hong Kong designated policyholder assets were moved into new fund code prefix funds as part of regulatory requirements to segregate Hong Kong designated assets from other jurisdictions.