Notification of changes to the underlying funds of various RobecoSAM Mirror Funds

26 Oct 2022

• L98 RobecoSAM Global Gender Equality Equities (USD) (the “Affected Mirror Fund 1”)
• L91 RobecoSAM Smart Energy (USD) (the “Affected Mirror Fund 2”)

(together the “Affected Mirror Funds 1-2”)

We have been notified by the Board of Directors of Robeco Capital Growth Funds (the “Company”) of the following upcoming changes to the underlying funds of the above Affected Mirror Funds. These changes will take effect on 28 October 2022 (the “Effective Date”).

Change to the Affected Mirror Fund 1
The Company has advised that under “Appendix I - Information per sub-fund” of the underlying fund's prospectus, the underlying fund of the Affected Mirror Fund 1 will be reclassified from Article 9 to Article 8 of Regulation (EU) 2019/2088 ("SFDR"), meaning the investment policy is amended to reflect that the underlying fund of the Affected Mirror Fund 1 will no longer have sustainable investment as its objective and that it will promote environmental and/or social characteristics.

This reclassification is made after due consideration and new insights on the regulatory interpretation, where the Company has decided to narrow the internal definition for sustainable investment to only positive Sustainable Development Goals ("SDG") scores. This technical redefinition automatically leads to reclassification of the underlying fund of the Affected Mirror Fund 1 from Article 9 to Article 8. The Company has advised that the strategy of the underlying fund of the Affected Mirror Fund 1 will remain unchanged.

Change to the Affected Mirror Fund 2
The Company has advised that under “Appendix VI - Benchmarks” of the underlying fund's prospectus, a Climate Transition Benchmark (CTB) has been added for the underlying fund of the Affected Mirror Fund 2. The Company is of the view that sub-funds classified as Article 9 SFDR with an explicit carbon objective are required to follow a Climate Transition Benchmark ("CTB") or a Paris Aligned Benchmark (PAB). As the objective of the underlying fund of the Affected Mirror Fund 2 explicitly names to contribute to Climate Action (SDG 3), a custom CTB has been added to measure the carbon target of the underlying fund of the Affected Mirror Fund 2.

Full details in relation to this notification can be found in the Robeco Capital Growth Funds notification opposite.

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