Correspondence 0001193125-22-312795 from Perpetual Americas Funds Trust (CIK 0001830437)
Perpetual Americas Funds Trust (CIK 0001830437)
Date: Dec. 27, 2022 · CIK: 0001830437 · Accession: 0001193125-22-312795
AI Filing Summary & Sentiment
File numbers found in text: 333-249784, 811-23615
Letter
VIA EDGAR Securities and Exchange Commission 100 F Street, NE Washington, DC 20549 Attn: Ms. Karen Rossotto Re: Post-Effective Amendment No. 7 to Registration Statement of JOHCM Funds Trust (File Nos. 811-23615 and 333-249784) on Form N-1A filed on October 6, 2022 (the “485(a) Filing”)
Dear Ms. Rossotto:
I am writing on behalf of JOHCM Funds Trust (the “Trust”) to respond to the comments by the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission,” or, the “SEC”) on post-effective amendment number 7 under the Securities Act of 1933 (the “1933 Act”) and amendment number 9 under the Investment Company Act of 1940 (the “1940 Act”) to the registration statement (the “Registration Statement”) of the Trust on Form N-1A filed on October 6, 2022 (the “Amendment”). The Amendment was filed for the purpose of registering for public offer and sale under the 1933 Act the Institutional Shares, Advisor Shares, Investor Shares, and Class Z Shares of the Regnan Sustainable Water and Waste Fund, a newly organized series of the Trust (the “Fund”).
On November 21, 2022, the Staff provided comments regarding the Amendment by telephone to the undersigned of Ropes & Gray LLP, counsel to the Trust. For convenience of reference, each comment is included before the Trust’s corresponding response. These responses will be reflected, to the extent applicable, in a post-effective amendment to the Trust’s Registration Statement, which the Trust intends to file on December 30, 2022. Capitalized terms not otherwise defined herein have the meanings ascribed to them in the Registration Statement. Existing disclosures below that will be revised are reflected, as applicable, with the new text underlined and the deleted text shown in strikethrough.
I. Prospectus Comments
General
1. Comment: The Staff observes that “waste” can refer to liquid, solid and gaseous forms and it can involve multiple resources. Consider if you believe it necessary for investor understanding to detail further what the Fund defines as “waste.”
Response: The referenced disclosure will be revised as reflected in Appendix A hereto, which shows cumulative revisions to the Item 9 principal investment strategies disclosure for the Fund since the 485(a) Filing, and corresponding changes will be made in the Fund summary.
2. Comment: Please provide the Staff with the Fund’s completed Fees and Expenses table and expense examples prior to the effective date of the Registration Statement.
Response: The Fund’s completed annual fund operating expenses tables and expense examples are set forth in Appendix B to this letter.
3. Comment: In footnote 2 to the Fees and Expenses table, consider whether the phrasing of the exclusions to “Total Annual Fund Operating Expenses” is appropriate or correct when related to the calculation of recapture.
Response: The restatement of the exclusions in footnote 2 is factually correct and matches those items marked as excluded from the Fee Waiver and Expense Reimbursement in Section 1 of the Fund’s Expense Limitation Agreement.1 The Fund therefore respectfully declines to revise this disclosure.
Principal Investment Strategies
4. Comment: Please further disclose, in either the Fund Summary or Item 9 section of the Registration Statement, what the Fund believes “global water- or waste-related challenges” are.
Response: The Trust will revise the investment strategy discussion of water- or waste-related challenges as follows (throughout this comment response letter, new language denoted by underline and deletions by strikethrough):
Footnote 2 to the Fees and Expenses table reads, in relevant part, as follows: “JOHCM (USA) Inc (the “Adviser”) has contractually agreed to waive fees and reimburse expenses to the extent that Total Annual Fund Operating Expenses (excluding brokerage costs, interest, taxes, dividends, litigation and indemnification expenses, expenses associated with investments in underlying investment companies, and extraordinary expenses) exceed 0.89%, 0.99%, 1.14%, and 0.89% for Institutional Shares, Advisor Shares, Investor Shares, and Class Z Shares, respectively, until January 31, 2024.”
December 27, 2022
The portfolio managers monitor around 350 companies that make up the Fund’s current investment universe and seek to identify companies along the water and waste value chains that, in their opinion, provide solutions to global water- or waste-related challenges. The portfolio managers consider water-related challenges to include but not be limited to: improving access to drinking water, repairing and maintaining water transportation infrastructure and advancing water treatment processes. The portfolio managers consider waste-related challenges to include but not be limited to: improving waste management safety and efficiency and finding sustainable solutions to capacity constraints relating to the management of waste in any of its forms.
5. Comment: Please explain supplementally how the Fund intends to allocate investments between each of the water and waste industries.
Response: The Fund does not target a specific allocation; rather the allocation between water and waste themes is an output of the portfolio managers’ bottom-up stock selection process and active strategy, as described in in the Principal Investment Strategies section of the Prospectus. Please see the Trust’s response to Comment 11, which includes revised disclosure relating to this Comment 5.
6. Comment: Please disclose how the Fund evaluates a company’s “potential to contribute solutions to global water- or waste-related challenges”.
Response: The portfolio managers look at a company’s activities to determine whether such activities are part of the process of addressing water- or waste-related challenges. The referenced disclosure will be revised in the Fund Summary and in the Item 9 section of the Registration Statement as follows:
The Fund seeks to achieve its investment objective by investing primarily in a global equity portfolio of companies the Adviser portfolio managers believes, based on such companies’ activities and public disclosures, have the potential to contribute solutions to global water- or waste-related challenges and which the Adviser believes satisfy itstheir criteria for possessing sustainable attributes (as described further below).
7. Comment: The Fund’s 80% investment policy states:
“The Fund invests, under normal circumstances, at least 80% of its assets (net assets plus the amount of borrowings for investment purposes) in equity securities of companies that have a material business involvement in water or waste solutions and that meet the portfolio managers’ sustainability criteria. The portfolio managers consider business involvement in water or waste solutions to be material if at least 40% of a company’s activities (as measured by sales, earnings, or similar metrics) are derived from a product or service related to water or waste solutions.”
December 27, 2022
For purposes of a fund’s 80% test, it is the Staff’s position that sales, earnings, etc., must be at least 50% of a company’s activity.
Response: The referenced disclosure will be updated to reflect a 50% threshold, as shown in the revised disclosure in Appendix A.
8. Comment: Please clarify the term “related to” in the Fund’s 80% investment policy. The definition of this term should indicate that the economic fortunes of the issuer are tied to water or waste solutions.
Response: A product or service “related to water or waste solutions” is one that is in the water or waste value chain and that addresses water or waste solutions. The referenced disclosure will be updated as shown in the revised disclosure in Appendix A. The term “related to” has been replaced in the revised disclosure.
9. Comment: The term “related” is also used multiple times in the bullet points within the Fund’s principal investment strategies. Please consider replacing this term in order to more precisely define what companies are included as water or waste solutions in the Fund’s investment strategy.
Response: Please see the Trust’s response to Comment 4. The Trust believes that the specific examples of water- and waste-related challenges that have been incorporated in the investment strategy disclosure provide related context and are responsive to the precise meaning of the Trust’s use of the word “related.”
10. Comment: The Fund states that the portfolio managers use a “rigorous stock-selection process that combines bottom-up analysis of business quality, a valuation assessment of absolute upside potential and ESG research.” Please further elaborate on the investment process. For example, are securities first evaluated using bottom-up analysis and then sustainability metrics are applied? Also, please identify what types of factors you are using in your bottom-up analysis.
Response: The bottom-up and sustainability analyses happen simultaneously to each other. A stock must meet minimum standards on both the fundamental and sustainability analyses to be eligible for inclusion in the Fund’s portfolio. ESG research is an integrated part of the overall investment process.
The referenced disclosure will be revised as follows:
The portfolio managers analyze specific companies through a rigorous stock-selection process that simultaneously combines bottom-up analysis of business quality, a valuation assessment of absolute upside potential and ESG research to construct a portfolio that normally holds between 35 and 50of 35-30 stocks. The bottom-up analysis includes considerations such as revenue model analysis, profit analysis, history of cash generation, and balance sheet assessment to assess the valuation and appropriateness of candidates for inclusion in the portfolio.
December 27, 2022
11. Comment: The Fund uses the phrases “strong sector positioning” and “strong balance sheet and demonstrated cash generation.” Please disclose what these phrases mean and the data and criteria used as part of the Fund’s bottom-up analysis of business quality. Additionally, please explain how the Fund creates a valuation assessment of “absolute upside potential” and what this phrase means. Please make applicable revisions in the Fund summary and Item 9 disclosure, as appropriate.
Response: “Strong sector positioning” refers to the market position of a company within its sector, for example the market share of a water pipe manufacturer within the region that it operates in. Qualitative factors such as relationships with distributors and clients will also be a consideration in sector positioning.
“Strong balance sheet and demonstrated cash generation” refers to the fact that the portfolio managers consider various aspects in determining the strength of a balance sheet and history of cash generation of a company the Fund is considering investing in. It includes net debt to EBITDA, which shows the company’s ability to pay its debt using earnings. The portfolio managers also consider whether the company has the ability to pay back its short-term liabilities with its short-term assets. The portfolio managers consider cash on the balance sheet to indicate an ability for a company to meet its short and long-term needs.
The portfolio managers use five valuation techniques used to measure a company’s “absolute upside potential” (the maximum amount by which they expect the price of a stock may increase): (1) Normalized P/E, (2) Dividend Discount Model, (3) Discounted Cash Flows, (4) Sum-of-the-Parts and (5) Free Cash Flow Yield. The portfolio managers believe that the market is semi-efficient and that they can use fundamental analysis to find securities that have not been correctly priced. The absolute upside potential is calculated as the percentage increase in value from the current share price to the portfolio managers’ intrinsic value using the foregoing techniques.
The disclosure in the Fund Summary and Item 9 section of the Registration Statement will be revised to reflect the above explanations as follows:
In identifying potential investments, the portfolio managers ordinarily look for companies that exhibit some or all of the following characteristics: a focus on the waste and water investment theme, a strong market position of such company within its sector positioning, a sustainable business model, high quality management, a strong balance sheet and, including the company’s ability to satisfy its short-term liabilities, and a demonstrated history of cash generation. The investment process does not target any particular allocation as between water solutions and waste solutions, and the mix of investments as between those two themes can vary significantly over time. The portfolio managers typically intend to hold
December 27, 2022
investments for 3-5 years or more. Although the Fund is a global, unconstrained Fund which can invest in emerging markets and frontier markets as well as developed markets—and althoughwhile the Fund does not apply a minimum or maximum limit on exposure to any single country—it is expected that the majority of the Fund’s holdings will be located in developed markets.
The Trust believes its answer to Comment 10 above is responsive to the question of data and criteria used as part of the Fund’s bottom-up analysis of business quality.
12. Comment: Please confirm supplementally if the environmental, social and governance (“ESG”) exclusionary screening (“ESG Screening”) is applied to all investments.
Response: The Fund confirms that ESG Screening is applied to all investments other than cash.
13. Comment: Under “Sustainability”, the Fund states that “[t]he portfolio managers . . . use both quantitative and qualitative factors to form an assessment of a company’s ‘sustainable’ attributes.” Please describe the Fund’s due diligence and practices in applying the screening criteria, including the underlying data that the Fund will review to determine if an issuer meets the Fund’s criteria and the sources of such data.
Response: In the Fund Summary and in the Item 9 section of the Registration Statement, the Trust will revise the referenced disclosure as follows:
The portfolio managers then use both quantitative and qualitative factors to form an assessment of a company’s “sustainable” attributes, including for example audit data, workplace health and safety and remuneration.
Additionally, the following disclosure will be added under a new sub-section “More Information about Investment Strategies Related to the Fund” in the Prospectus:
ESG Diligence Process. To determine whether an issuer meets the Fund’s criteria for possessing a given environmental, social and governance attribute, a suite of core factors promotes comprehensive evaluation while also providing flexibility to incorporate company specific and novel considerations for each environmental, social or governance theme. Environment factors include, for example, climate transition, physical impacts of climate change, water security and other environmental management. Social factors include, for example, human capital management and workplace health and safety. Governance factors include, for example, ethical conduct, board skills, structures and management, audit data, remuneration and other corporate governance.
December 27, 2022
Each new investment is assigned an MSCI ESG rating and/or a Sustainable Value Assessment (“SVA”), an internal ESG assessment. In producing ratings, the Fund draws on a broad range of public data sources, such as company filings, MSCI ESG ratings and third-party data providers such as Sustainalytics, a leading independent ESG analytics firm. This enables the Fund
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CORRESP 1 filename1.htm CORRESP ROPES & GRAY LLP PRUDENTIAL TOWER 800 BOYLSTON STREET BOSTON, MA 02199-3600 WWW.ROPESGRAY.COM December 27, 2022 Angela C. Jaimes T +1 617 951 7591 angela.jaimes@ropesgray.com VIA EDGAR Securities and Exchange Commission 100 F Street, NE Washington, DC 20549 Attn: Ms. Karen Rossotto Re: Post-Effective Amendment No. 7 to Registration Statement of JOHCM Funds Trust (File Nos. 811-23615 and 333-249784) on Form N-1A filed on October 6, 2022 (the “485(a) Filing”) Dear Ms. Rossotto: I am writing on behalf of JOHCM Funds Trust (the “Trust”) to respond to the comments by the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission,” or, the “SEC”) on post-effective amendment number 7 under the Securities Act of 1933 (the “1933 Act”) and amendment number 9 under the Investment Company Act of 1940 (the “1940 Act”) to the registration statement (the “Registration Statement”) of the Trust on Form N-1A filed on October 6, 2022 (the “Amendment”). The Amendment was filed for the purpose of registering for public offer and sale under the 1933 Act the Institutional Shares, Advisor Shares, Investor Shares, and Class Z Shares of the Regnan Sustainable Water and Waste Fund, a newly organized series of the Trust (the “Fund”). On November 21, 2022, the Staff provided comments regarding the Amendment by telephone to the undersigned of Ropes & Gray LLP, counsel to the Trust. For convenience of reference, each comment is included before the Trust’s corresponding response. These responses will be reflected, to the extent applicable, in a post-effective amendment to the Trust’s Registration Statement, which the Trust intends to file on December 30, 2022. Capitalized terms not otherwise defined herein have the meanings ascribed to them in the Registration Statement. Existing disclosures below that will be revised are reflected, as applicable, with the new text underlined and the deleted text shown in strikethrough. I. Prospectus Comments General 1. Comment: The Staff observes that “waste” can refer to liquid, solid and gaseous forms and it can involve multiple resources. Consider if you believe it necessary for investor understanding to detail further what the Fund defines as “waste.” Response: The referenced disclosure will be revised as reflected in Appendix A hereto, which shows cumulative revisions to the Item 9 principal investment strategies disclosure for the Fund since the 485(a) Filing, and corresponding changes will be made in the Fund summary. 2. Comment: Please provide the Staff with the Fund’s completed Fees and Expenses table and expense examples prior to the effective date of the Registration Statement. Response: The Fund’s completed annual fund operating expenses tables and expense examples are set forth in Appendix B to this letter. 3. Comment: In footnote 2 to the Fees and Expenses table, consider whether the phrasing of the exclusions to “Total Annual Fund Operating Expenses” is appropriate or correct when related to the calculation of recapture. Response: The restatement of the exclusions in footnote 2 is factually correct and matches those items marked as excluded from the Fee Waiver and Expense Reimbursement in Section 1 of the Fund’s Expense Limitation Agreement.1 The Fund therefore respectfully declines to revise this disclosure. Principal Investment Strategies 4. Comment: Please further disclose, in either the Fund Summary or Item 9 section of the Registration Statement, what the Fund believes “global water- or waste-related challenges” are. Response: The Trust will revise the investment strategy discussion of water- or waste-related challenges as follows (throughout this comment response letter, new language denoted by underline and deletions by strikethrough): 1 Footnote 2 to the Fees and Expenses table reads, in relevant part, as follows: “JOHCM (USA) Inc (the “Adviser”) has contractually agreed to waive fees and reimburse expenses to the extent that Total Annual Fund Operating Expenses (excluding brokerage costs, interest, taxes, dividends, litigation and indemnification expenses, expenses associated with investments in underlying investment companies, and extraordinary expenses) exceed 0.89%, 0.99%, 1.14%, and 0.89% for Institutional Shares, Advisor Shares, Investor Shares, and Class Z Shares, respectively, until January 31, 2024.” 2 December 27, 2022 The portfolio managers monitor around 350 companies that make up the Fund’s current investment universe and seek to identify companies along the water and waste value chains that, in their opinion, provide solutions to global water- or waste-related challenges. The portfolio managers consider water-related challenges to include but not be limited to: improving access to drinking water, repairing and maintaining water transportation infrastructure and advancing water treatment processes. The portfolio managers consider waste-related challenges to include but not be limited to: improving waste management safety and efficiency and finding sustainable solutions to capacity constraints relating to the management of waste in any of its forms. 5. Comment: Please explain supplementally how the Fund intends to allocate investments between each of the water and waste industries. Response: The Fund does not target a specific allocation; rather the allocation between water and waste themes is an output of the portfolio managers’ bottom-up stock selection process and active strategy, as described in in the Principal Investment Strategies section of the Prospectus. Please see the Trust’s response to Comment 11, which includes revised disclosure relating to this Comment 5. 6. Comment: Please disclose how the Fund evaluates a company’s “potential to contribute solutions to global water- or waste-related challenges”. Response: The portfolio managers look at a company’s activities to determine whether such activities are part of the process of addressing water- or waste-related challenges. The referenced disclosure will be revised in the Fund Summary and in the Item 9 section of the Registration Statement as follows: The Fund seeks to achieve its investment objective by investing primarily in a global equity portfolio of companies the Adviser portfolio managers believes, based on such companies’ activities and public disclosures, have the potential to contribute solutions to global water- or waste-related challenges and which the Adviser believes satisfy itstheir criteria for possessing sustainable attributes (as described further below). 7. Comment: The Fund’s 80% investment policy states: “The Fund invests, under normal circumstances, at least 80% of its assets (net assets plus the amount of borrowings for investment purposes) in equity securities of companies that have a material business involvement in water or waste solutions and that meet the portfolio managers’ sustainability criteria. The portfolio managers consider business involvement in water or waste solutions to be material if at least 40% of a company’s activities (as measured by sales, earnings, or similar metrics) are derived from a product or service related to water or waste solutions.” 3 December 27, 2022 For purposes of a fund’s 80% test, it is the Staff’s position that sales, earnings, etc., must be at least 50% of a company’s activity. Response: The referenced disclosure will be updated to reflect a 50% threshold, as shown in the revised disclosure in Appendix A. 8. Comment: Please clarify the term “related to” in the Fund’s 80% investment policy. The definition of this term should indicate that the economic fortunes of the issuer are tied to water or waste solutions. Response: A product or service “related to water or waste solutions” is one that is in the water or waste value chain and that addresses water or waste solutions. The referenced disclosure will be updated as shown in the revised disclosure in Appendix A. The term “related to” has been replaced in the revised disclosure. 9. Comment: The term “related” is also used multiple times in the bullet points within the Fund’s principal investment strategies. Please consider replacing this term in order to more precisely define what companies are included as water or waste solutions in the Fund’s investment strategy. Response: Please see the Trust’s response to Comment 4. The Trust believes that the specific examples of water- and waste-related challenges that have been incorporated in the investment strategy disclosure provide related context and are responsive to the precise meaning of the Trust’s use of the word “related.” 10. Comment: The Fund states that the portfolio managers use a “rigorous stock-selection process that combines bottom-up analysis of business quality, a valuation assessment of absolute upside potential and ESG research.” Please further elaborate on the investment process. For example, are securities first evaluated using bottom-up analysis and then sustainability metrics are applied? Also, please identify what types of factors you are using in your bottom-up analysis. Response: The bottom-up and sustainability analyses happen simultaneously to each other. A stock must meet minimum standards on both the fundamental and sustainability analyses to be eligible for inclusion in the Fund’s portfolio. ESG research is an integrated part of the overall investment process. The referenced disclosure will be revised as follows: The portfolio managers analyze specific companies through a rigorous stock-selection process that simultaneously combines bottom-up analysis of business quality, a valuation assessment of absolute upside potential and ESG research to construct a portfolio that normally holds between 35 and 50of 35-30 stocks. The bottom-up analysis includes considerations such as revenue model analysis, profit analysis, history of cash generation, and balance sheet assessment to assess the valuation and appropriateness of candidates for inclusion in the portfolio. 4 December 27, 2022 11. Comment: The Fund uses the phrases “strong sector positioning” and “strong balance sheet and demonstrated cash generation.” Please disclose what these phrases mean and the data and criteria used as part of the Fund’s bottom-up analysis of business quality. Additionally, please explain how the Fund creates a valuation assessment of “absolute upside potential” and what this phrase means. Please make applicable revisions in the Fund summary and Item 9 disclosure, as appropriate. Response: “Strong sector positioning” refers to the market position of a company within its sector, for example the market share of a water pipe manufacturer within the region that it operates in. Qualitative factors such as relationships with distributors and clients will also be a consideration in sector positioning. “Strong balance sheet and demonstrated cash generation” refers to the fact that the portfolio managers consider various aspects in determining the strength of a balance sheet and history of cash generation of a company the Fund is considering investing in. It includes net debt to EBITDA, which shows the company’s ability to pay its debt using earnings. The portfolio managers also consider whether the company has the ability to pay back its short-term liabilities with its short-term assets. The portfolio managers consider cash on the balance sheet to indicate an ability for a company to meet its short and long-term needs. The portfolio managers use five valuation techniques used to measure a company’s “absolute upside potential” (the maximum amount by which they expect the price of a stock may increase): (1) Normalized P/E, (2) Dividend Discount Model, (3) Discounted Cash Flows, (4) Sum-of-the-Parts and (5) Free Cash Flow Yield. The portfolio managers believe that the market is semi-efficient and that they can use fundamental analysis to find securities that have not been correctly priced. The absolute upside potential is calculated as the percentage increase in value from the current share price to the portfolio managers’ intrinsic value using the foregoing techniques. The disclosure in the Fund Summary and Item 9 section of the Registration Statement will be revised to reflect the above explanations as follows: In identifying potential investments, the portfolio managers ordinarily look for companies that exhibit some or all of the following characteristics: a focus on the waste and water investment theme, a strong market position of such company within its sector positioning, a sustainable business model, high quality management, a strong balance sheet and, including the company’s ability to satisfy its short-term liabilities, and a demonstrated history of cash generation. The investment process does not target any particular allocation as between water solutions and waste solutions, and the mix of investments as between those two themes can vary significantly over time. The portfolio managers typically intend to hold 5 December 27, 2022 investments for 3-5 years or more. Although the Fund is a global, unconstrained Fund which can invest in emerging markets and frontier markets as well as developed markets—and althoughwhile the Fund does not apply a minimum or maximum limit on exposure to any single country—it is expected that the majority of the Fund’s holdings will be located in developed markets. The Trust believes its answer to Comment 10 above is responsive to the question of data and criteria used as part of the Fund’s bottom-up analysis of business quality. 12. Comment: Please confirm supplementally if the environmental, social and governance (“ESG”) exclusionary screening (“ESG Screening”) is applied to all investments. Response: The Fund confirms that ESG Screening is applied to all investments other than cash. 13. Comment: Under “Sustainability”, the Fund states that “[t]he portfolio managers . . . use both quantitative and qualitative factors to form an assessment of a company’s ‘sustainable’ attributes.” Please describe the Fund’s due diligence and practices in applying the screening criteria, including the underlying data that the Fund will review to determine if an issuer meets the Fund’s criteria and the sources of such data. Response: In the Fund Summary and in the Item 9 section of the Registration Statement, the Trust will revise the referenced disclosure as follows: The portfolio managers then use both quantitative and qualitative factors to form an assessment of a company’s “sustainable” attributes, including for example audit data, workplace health and safety and remuneration. Additionally, the following disclosure will be added under a new sub-section “More Information about Investment Strategies Related to the Fund” in the Prospectus: ESG Diligence Process. To determine whether an issuer meets the Fund’s criteria for possessing a given environmental, social and governance attribute, a suite of core factors promotes comprehensive evaluation while also providing flexibility to incorporate company specific and novel considerations for each environmental, social or governance theme. Environment factors include, for example, climate transition, physical impacts of climate change, water security and other environmental management. Social factors include, for example, human capital management and workplace health and safety. Governance factors include, for example, ethical conduct, board skills, structures and management, audit data, remuneration and other corporate governance. 6 December 27, 2022 Each new investment is assigned an MSCI ESG rating and/or a Sustainable Value Assessment (“SVA”), an internal ESG assessment. In producing ratings, the Fund draws on a broad range of public data sources, such as company filings, MSCI ESG ratings and third-party data providers such as Sustainalytics, a leading independent ESG analytics firm. This enables the Fund