Notification of changes to the underlying funds of various Robeco funds

15 Apr 2025

  • R238 Robeco Smart Energy (USD) (“Affected ILP sub-fund 1”)
  • R243 Robeco Sustainable Water (USD) (“Affected ILP sub-fund 2”)
  • R244 Robeco Sustainable Healthy Living (USD) (“Affected ILP sub-fund 3”) 
    (together the “Affected ILP sub-funds”)

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 ILP sub-funds. These changes will take effect from 7 May 2025 (the “Effective Date”). 

Background
The Company has advised that it is making a number of amendments to the prospectus of the underlying funds of the Affected ILP sub-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 ILP sub-funds 1-3
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 Appendix 1 of the sample client correspondence opposite for details of the updated text which will be applicable to the underlying funds of Affected ILP sub-funds 1-3.

Removal of sustainable benchmark of Affected ILP sub-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 ILP sub-funds 1-2
From the Effective Date, additional environmental/social characteristic, sustainability indicator and binding elements will be added to the underlying funds of Affected ILP sub-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 Appendix 2 of the sample client correspondence opposite for details of the updated text which will be applicable to the underlying funds of Affected ILP sub-funds 1-2.

Changes relating to Affected ILP sub-fund 3
The underlying fund of Affected ILP sub-fund 3 will be updated from the Effective Date, in order to comply with ESMA guidelines on fund names which include sustainability or ESG related terms. Affected ILP sub-fund 3 will also be renamed accordingly: 

Current ILP sub-fund nameUpdated ILP sub-fund name from Effective Date
R244 Robeco Sustainable Healthy Living (USD) R244 Robeco Healthy Living (USD)

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

Climate Transition Benchmarks incorporates 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 Appendix 3 of the sample client correspondence opposite for details of the updated text which will be applicable to the underlying fund of Affected ILP sub-fund 3.

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.

We have contacted impacted policyholders and their financial advisers to notify them of the change; primarily by e-shot, with letters sent by post where we do not hold a valid email, and to those who prefer to receive letters by post. A sample of the client communication can be found opposite.

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