Responsible Investing at Fisher Investments

FI considers ESG events or conditions that, if they occur, could cause a negative material impact on the value of an investment (“Sustainability Risk”), throughout the investment process.

FI believes that Sustainability Risk is not a standalone risk easily quantified at the security or portfolio level. Instead, Sustainability Risk manifests through other existing sustainability-related risk types, including but not limited to, political and economic factors, corruption and organised crime, ESG data reliance, and credit.  As a result, FI assesses that a strategy with more investments susceptible to these underlying risk types may have greater Sustainability Risks due to their geographic exposures which may increase or decrease over time. For example, if a strategy has significant exposure to emerging markets, it would be expected to make the strategy subject to higher than usual risks of political changes, government regulation, social instability or diplomatic developments (including war), which could adversely affect the economies of the relevant countries and thus the value of investments in those countries. Therefore, such strategy may have greater Sustainability Risk than strategies that do not have significant exposure to emerging markets.

These risks are integrated in FI’s investment process and risk management practices both qualitatively and quantitatively. Qualitatively, FI considers such risks when developing country, sector, and thematic preferences and in their bottom-up fundamental research. Quantitatively, FI attempts to quantify and monitor Sustainability Risks as part of FI’s risk management practices.

While FI believes its investment and risk management practices can help enhance portfolio relative performance, particularly in modifying exposure to countries, industries, and securities whose value may be materially impacted by a related risk, Sustainability Risks may nonetheless adversely impact a strategy’s performance.

Given that FII outsources the portfolio management function to FI, it is not currently envisaged that the consideration of Sustainability Risks will be of primary relevance to the functions performed by FII staff. Accordingly, FII does not currently anticipate consideration of Sustainability Risks as being a significant factor in the assessment of FII’s staff members’ variable remuneration.

Notwithstanding that the consideration of Sustainability Risks is integrated into FI’s investment decision-making process, by virtue of FII’s size, FII is not required and currently elects not to consider the adverse impacts of its investment decisions on environmental, social or employee matters, respect for human rights, or anti-corruption or anti-bribery matters (“Sustainability Factors”) in respect of all portfolios it manages. However, with respect to strategies that promote environmental or social characteristics or have a sustainable investment objective (a “Responsible Investment Strategy,” or “RI Strategy”), the sustainability-related disclosures provided below for each RI Strategy describes how principal adverse impacts on Sustainability Factors are considered by FI, including to what extent the indicators listed in Table 1 of Annex I of the Commission Delegated Regulation (EU) 2022/1288 (the “RTS”) are taken into consideration by FI. Furthermore, for institutional clients who have an RI Strategy implemented in their investment portfolio, such institutional clients will receive pre-contractual disclosures related to their investment portfolio that will describe how principal adverse impacts on Sustainability Factors are considered by FI in their investment portfolio.

FII makes available to its institutional clients certain Responsible Investment strategies (a “Responsible Investment Strategy,” or “RI Strategy”) that can be implemented in an institutional client’s investment portfolio. By implementing an RI Strategy in an institutional client’s investment portfolio, such portfolio is considered an Article 8 or Article 9 financial product under SFDR, which requires certain portfolio-specific disclosures to be provided on FII’s website. However, FII considers the management of its institutional client’s investment portfolio to be confidential, and will not publish portfolio-specific sustainability disclosures on its website. Instead, FII publishes the below information about the RI Strategies at the model level, which will include SFDR periodic reporting on the performance of such RI Strategies from a sustainability perspective.

• Article 8 Strategies
  • Fisher Investments Emerging Markets Equity ESG
  • Fisher Investments Emerging Markets Equity Paris Aligned
  • Fisher Investments Emerging Markets Responsible Equity
  • Fisher Investments Global Developed Concentrated Equity ESG
  • Fisher Investments Global Developed Equity ESG
  • Fisher Investments Global Developed Equity ESG Values
  • Fisher Investments Global Equity ESG
  • Fisher Investments Global Ex-US Equity ESG
  • Fisher Investments Global Small Cap Equity ESG
  • Fisher Investments Global Responsible Equity ESG
  • Fisher Investments Quantitative Global Equity ESG
  • Fisher Investments US All Cap Equity ESG
  • Fisher Investments US Equity ESG
  • Fisher Investments US Small Cap Core Equity ESG
  • Fisher Investments US Small & Mid Cap Core Equity ESG
  • Translations: Please click here to view translated summaries for each of these sustainability-related disclosures.

• Article 9 Strategies
  • Fisher Investments Global Sustainable Equity Impact
  • Translations: Please click here to view translated summaries for each of these sustainability-related disclosures.

Should any changes be made to this disclosure in the future, a clear explanation of such changes will be published here.

Implemented Changes

In January 2022, this disclosure was updated to:

• reflect the postponement of the RTS effective date to January 2023;
• address SFDR and Taxonomy Regulation periodic reporting; and
• modify the strategy line-up in the Sustainability-Related Disclosures section; and
• adding disclosures regarding the Taxonomy Regulation.

In December 2022, this disclosure was updated to:

• update the sustainability-related disclosures for the Responsible Investment Strategies to comply with the RTS;
• remove the principal adverse impact statement that was originally posted to comply with SFDR on a high level, principles basis; and
• remove disclosures not required under SFDR or the Taxonomy Regulation (Regulation EU/2020/852).

In February 2026, this disclosure was updated to:

• update the Investment Manager’s Responsible Investment Policy Statement (formerly the ESG Policy Statement); and
• update the terminology to better align with defined terms from FI and FII.

Date of Publication: 9 February 2026