Details of Significant Events
Columbia Threadneedle (Lux) I; Columbia Threadneedle (Lux) II

Contents

Columbia Threadneedle (Lux) I.......................................................................................................................................................... 3
CT (Lux) American............................................................................................................................................................................ 3
CT (Lux) American Extended Alpha ................................................................................................................................................. 4
CT (Lux) American Select ................................................................................................................................................................ 4
CT (Lux) American Smaller Companies ........................................................................................................................................... 5
CT (Lux) Asia Equities ...................................................................................................................................................................... 8
CT (Lux) Asian Equity Income ........................................................................................................................................................ 11
CT (Lux) Credit Opportunities ........................................................................................................................................................ 12
CT (Lux) Emerging Market Corporate Bonds ................................................................................................................................. 12
CT (Lux) Emerging Market Debt..................................................................................................................................................... 12
CT (Lux) Enhanced Commodities .................................................................................................................................................. 12
CT (Lux) European Corporate Bond............................................................................................................................................... 12
CT (Lux) European High Yield Bond.............................................................................................................................................. 13
CT (Lux) European Select .............................................................................................................................................................. 17
CT (Lux) European Short-Term High Yield Bond ........................................................................................................................... 21
CT (Lux) European Smaller Companies......................................................................................................................................... 21
CT (Lux) European Social Bond ..................................................................................................................................................... 25
CT (Lux) European Strategic Bond ................................................................................................................................................ 28
CT (Lux) Flexible Asian Bond ......................................................................................................................................................... 28
CT (Lux) Global Corporate Bond .................................................................................................................................................... 28
CT (Lux) Global Dynamic Real Return ........................................................................................................................................... 30
CT (Lux) Global Emerging Market Equities ................................................................................................................................... 30
CT (Lux) Global Emerging Market Short-Term Bonds................................................................................................................... 31
CT (Lux) Global Equity Income ...................................................................................................................................................... 31
CT (Lux) Global Extended Alpha .................................................................................................................................................... 34
CT (Lux) Global Focus ................................................................................................................................................................... 34
CT (Lux) Global Investment Grade Credit Opportunities................................................................................................................. 38
CT (Lux) Global Multi Asset Income ............................................................................................................................................... 38
CT (Lux) Global Select ................................................................................................................................................................... 40
CT (Lux) Global Social Bond .......................................................................................................................................................... 43
CT (Lux) Global Smaller Companies .............................................................................................................................................. 43
CT (Lux) Global Technology........................................................................................................................................................... 47
CT (Lux) Japan Equities ................................................................................................................................................................. 48
CT (Lux) Pan European Absolute Alpha ........................................................................................................................................ 48
CT (Lux) Pan European Equity Dividend........................................................................................................................................ 48
1

Details of Significant Events
Columbia Threadneedle (Lux) I; Columbia Threadneedle (Lux) II
CT (Lux) Pan European ESG Equities ........................................................................................................................................... 48
CT (Lux) Pan European Small Cap Opportunities .......................................................................................................................... 50
CT (Lux) Pan European Smaller Companies ................................................................................................................................. 52
CT (Lux) UK Equities ...................................................................................................................................................................... 55
CT (Lux) UK Equity Income ............................................................................................................................................................ 56
CT (Lux) US Contrarian Core Equities ........................................................................................................................................... 56
CT (Lux) US Disciplined Core Equities........................................................................................................................................... 57
CT (Lux) US High Yield Bond ......................................................................................................................................................... 57
Columbia Threadneedle (Lux) II....................................................................................................................................................... 58
CT (Lux) Sustainable Outcomes Global Equity .............................................................................................................................. 58

2

Details of Significant Events
Columbia Threadneedle (Lux) I; Columbia Threadneedle (Lux) II

Columbia Threadneedle (Lux) I
Portfolio Name

Date of
Significant Details before Significant Event
Event
02/09/2024

Details after Significant Event

Change to minimum proportion of assets insustainable investments:

Change to minimum proportion of assets insustainable investments:

5%20%Further information is available in the SFDR RTS Annexof the Prospectus.

20/11/2023

20/11/2023

CT (Lux) American

Name change:

Name change:

Threadneedle (Lux) – American

CT (Lux) American

Investment objective and policy change:

Investment objective and policy change:

The American Portfolio seeks to achieve capital
appreciation. It looks to outperform the S&P 500 Index
after the deduction of charges.

The American Portfolio seeks to achieve capital
appreciation. It looks to outperform the S&P 500 Index
after the deduction of charges.

The Portfolio is actively managed and invests principallyin shares of companies domiciled in the US or whichhave significant US business operations. The Portfolio
may further invest in other securities (including fixedincome securities, other equities and Money Market
Instruments).

The Portfolio is actively managed and invests principallyin shares of companies domiciled in the US or whichhave significant US business operations. The Portfolio
may further invest in other securities (including fixedincome securities, other equities and Money Market
Instruments).

The Portfolio may use financial derivative instruments
for hedging purposes.

The Portfolio may use financial derivative instruments
for hedging purposes.

The Portfolio selects companies considered to havegood prospects for share price growth, from any
industry or economic sector, and whilst there is norestriction on size, investment tends to focus on larger
companies, such as those included in the S&P 500
Index.

The Portfolio selects companies considered to havegood prospects for share price growth, from any
industry or economic sector, and whilst there is norestriction on size, investment tends to focus on larger
companies, such as those included in the S&P 500
Index.

For the purposes of managing liquidity, the Portfolio
may hold ancillary liquid assets (i.e. bank deposit atsight), and may hold bank deposits, money market
instruments or money market funds for treasury
purposes. In normal market conditions, investments inancillary liquid assets, bank deposits, money market
instruments or money market funds will not exceed 10%of the Portfolio's net asset value.

For the purposes of managing liquidity, the Portfolio
may hold ancillary liquid assets (i.e. bank deposits atsight), and may also hold bank deposits, Money Market
Instruments or money market funds for treasury
purposes. In normal market conditions, investments inthese assets or instruments will not exceed 10% of thePortfolio's Net Asset Value.

The Portfolio is actively managed in reference to the
S&P 500 Index. The index is broadly representative of
the companies in which the Portfolio invests, andprovides a suitable target benchmark against which
Portfolio performance will be measured and evaluatedover time. The Sub-Advisor has discretion to selectinvestments with weightings different to the index, andthat are not in the index, and the Portfolio may display
significant divergence from the index.
Deviations from the index, including guidance on thelevel of risk relative to the index, will be considered aspart of the Sub-Advisor’s risk monitoring process, toensure the overall level of risk is broadly consistent with
the index. In line with its active management strategy,
there may be significant deviation from the index.

The Portfolio is actively managed in reference to the
S&P 500 Index. The index is broadly representative of
the companies in which the Portfolio invests, andprovides a suitable target benchmark against which
Portfolio performance will be measured and evaluatedover time. The index is not designed to specificallyconsider environmental or social characteristics.
The Sub-Advisor has discretion to select investmentswith weightings different to the index, and that are not in
the index, and the Portfolio may display significant
divergence from the index.
Deviations from the index, including guidance on thelevel of risk relative to the index, will be considered aspart of the Sub-Advisor’s risk monitoring process.
Promotion of Environmental and Social
Characteristics
The Sub-Advisor promotes environmental and social
characteristics by integrating a range of responsible
investment measures into the investment decisionmaking process, as well as ensuring that the companies
in which the Portfolio invests follow good governance3

Details of Significant Events
Columbia Threadneedle (Lux) I; Columbia Threadneedle (Lux) II

Columbia Threadneedle (Lux) I
Portfolio Name

Date of
Significant Details before Significant Event
Event

Details after Significant Event
practices.
Information about the environmental or social
characteristics promoted by the Portfolio and theirintegration into the investment process is available in
the SFDR RTS Annex of the Prospectus.

01/12/2011

01/12/2011

CT (Lux) American Extended Alpha

20/11/2023

02/09/2024

Name change:

Name change:

Threadneedle (Lux) – US Equities

Threadneedle (Lux) – American

Investment objective and policy change:

Investment objective and policy change:

The US Equities Portfolio seeks to achieve capital
appreciation by investing principally in a diversified
portfolio of equity securities corporate issuers
headquartered in the United States or exercising a
predominant part of their activity in this country.
Secondarily, the Portfolio may invest in other securities
convertible into equity securities and/or warrants. The
securities will generally be of companies withcapitalisations that are similar to those of companies
represented in the S&P 500 Index.

The American Portfolio seeks to achieve capital
appreciation by investing principally in the equity
securities of medium to large companies domiciled in
North America or with significant North American
operations. The Portfolio may further invest in othersecurities (including fixed income securities, other
equities and Money Market Instruments).

Name change:

Name change:

Threadneedle (Lux) – American Extended Alpha

CT (Lux) American Extended Alpha

Change to minimum proportion of assets insustainable investments:

Change to minimum proportion of assets insustainable investments:

5%20%Further information is available in the SFDR RTS Annexof the Prospectus.

20/11/2023

CT (Lux) American SelectName change:

Name change:

Threadneedle (Lux) – American SelectCT (Lux) American SelectInvestment objective and policy change:

Investment objective and policy change:

The American Select Portfolio seeks to achieve capital
appreciation by investing principally in the equity
securities of companies domiciled in North America or
which have significant North American operations. Thesemay include large, medium and smaller companies.
There will be no particular specialisation. The selectinvestment approach means that the Portfolio has theflexibility to take significant stock and sector positions
which may lead to increased levels of volatility.

The American Select Portfolio seeks to achieve capital
appreciation by investing principally in the equity
securities of companies domiciled in North America or
which have significant North American operations.
These may include large, medium and smaller
companies. There will be no particular specialisation.
The select investment approach means that thePortfolio has the flexibility to take significant stock andsector positions which may lead to increased levels ofvolatility.

For the purposes of managing liquidity, the Portfolio may
hold ancillary liquid assets (i.e. bank deposit at sight),
and may hold bank deposits, money market instruments
or money market funds for treasury purposes. In normal
market conditions, investments in ancillary liquid assets,bank deposits, money market instruments or money
market funds will not exceed 10% of the Portfolio's net
asset value.
The Portfolio is actively managed in reference to the S&P
500 Index. The index is broadly representative of thecompanies in which the Portfolio invests, and provides asuitable target benchmark against which Portfolio
performance will be measured and evaluated over time.

4

For the purposes of managing liquidity, the Portfolio
may hold ancillary liquid assets (i.e. bank deposits atsight), and may also hold bank deposits, Money Market
Instruments or money market funds for treasury
purposes. In normal market conditions, investments inthese assets or instruments will not exceed 10% of thePortfolio's Net Asset Value.
The Portfolio is actively managed in reference to the
S&P 500 Index. The index is broadly representative of
the companies in which the Portfolio invests, andprovides a suitable target benchmark against which
Portfolio performance will be measured and evaluatedover time. The index is not designed to specificallyDetails of Significant Events
Columbia Threadneedle (Lux) I; Columbia Threadneedle (Lux) II

Columbia Threadneedle (Lux) I
Portfolio Name

Date of
Significant Details before Significant Event
Event
The Sub-Advisor has discretion to select investmentswith weightings different to the index, and that are not in
the index, and the Portfolio may display significant
divergence from the index.
Deviations from the index, including guidance on thelevel of risk relative to the index, will be considered aspart of the Sub-Advisor’s risk monitoring process, toensure the overall level of risk is broadly consistent with
the index. In line with its active management strategy,
there may be significant deviation from the index.

Details after Significant Eventconsider environmental or social characteristics.
The Sub-Advisor has discretion to select investmentswith weightings different to the index, and that are not in
the index, and the Portfolio may display significant
divergence from the index.
Deviations from the index, including guidance on thelevel of risk relative to the index, will be considered aspart of the Sub-Advisor’s risk monitoring process.
Promotion of Environmental and Social
Characteristics
The Sub-Advisor promotes environmental and social
characteristics by integrating a range of responsible
investment measures into the investment decisionmaking process, as well as ensuring that the companies
in which the Portfolio invests follow good governancepractices.
Information about the environmental or social
characteristics promoted by the Portfolio and theirintegration into the investment process is available in
the SFDR RTS Annex of the Prospectus.

02/09/2024

Change to minimum proportion of assets insustainable investments:

Change to minimum proportion of assets insustainable investments:

5%10%Further information is available in the SFDR RTS Annexof the Prospectus.

20/11/2023

20/11/2023

CT (Lux) American Smaller
Companies

Name change:

Name change:

Threadneedle (Lux) – American Smaller Companies

CT (Lux) American Smaller Companies

Investment objective and policy change:

Investment objective and policy change:

The American Smaller Companies Portfolio seeks toachieve capital appreciation by investing principally inshares issued by American Smaller Companies that are
domiciled in the United States or have significant US
operations.

The American Smaller Companies Portfolio seeks toachieve capital appreciation by investing principally inshares issued by American Smaller Companies that are
domiciled in the United States or have significant US
operations.

The Portfolio may use financial derivative instruments for The Portfolio may use financial derivative instruments forhedging purposes.
hedging purposes.
The Portfolio is actively managed in reference to theRussell 2500 Index. The index is broadly representativeof the companies in which the Portfolio invests, andprovides a suitable target benchmark against which
Portfolio performance will be measured and evaluatedover time. The Portfolio promotes environmental andsocial characteristics by aiming to compare favourably
against the index over rolling 12-month periods whenassessed according to the Columbia Threadneedle ESG
Materiality Rating, as set out below. The index is notdesigned to specifically consider environmental or social
characteristics. The Sub-Advisor has discretion to selectinvestments with weightings different to the index, andthat are not in the index, and the Portfolio may display
significant divergence from the index.
Deviations from the index, including guidance on thelevel of risk relative to the index, will be considered aspart of the Sub-Advisor’s risk monitoring process, to

5

For the purposes of managing liquidity, the Portfolio may
hold ancillary liquid assets (i.e. bank deposits at sight),
and may also hold bank deposits, Money Market
Instruments or money market funds for treasury
purposes. In normal market conditions, investments inthese assets or instruments will not exceed 10% of thePortfolio’s Net Asset Value.
The Portfolio is actively managed in reference to theRussell 2500 Index. The index is broadly representativeof the companies in which the Portfolio invests, andprovides a suitable target benchmark against which
Portfolio performance will be measured and evaluatedover time. The index is not designed to specificallyconsider environmental or social characteristics.
The Sub-Advisor has discretion to select investmentswith weightings different to the index, and that are not in
the index, and the Portfolio may display significant
divergence from the index.

Details of Significant Events
Columbia Threadneedle (Lux) I; Columbia Threadneedle (Lux) II

Columbia Threadneedle (Lux) I
Portfolio Name

Date of
Significant Details before Significant Event
Event
ensure the overall level of risk is broadly consistent with
the index. In line with its active management strategy,
there may be significant deviation from the index.
Promotion of Environmental and Social
Characteristics
The Sub-Advisor promotes environmental and social
characteristics by integrating a range of responsible
investment measures into the investment decisionmaking process.
Over rolling 12-month periods, the Portfolio aims tocompare favourably with the Russell 2500 Index
according to the Columbia Threadneedle ESG Materiality
Rating - a proprietary model which builds on the
Sustainability and Accounting Standards Board (SASB®)
framework. This model identifies material environmental,social and governance (“ESG”) factors across a broad
range of sectors, and provides an insight into the
management focus and standards of operating practicesof a company. The Sub-Advisor considers thatcompanies that manage ESG risks effectively are better
positioned to address future challenges, and capitaliseon unknown and known future business opportunities.
Companies that lead on the most material ESG metrics
should be well positioned to build competitive advantage
and sustain their long-term future.
The Portfolio also aims to exclude companies thatbreach accepted international standards and principles(e.g. the United Nations Global Compact). Companies inbreach may be assessed as suitable for investment by
the Portfolio, if in the opinion of the Sub-Advisor there
are tangible mitigating factors for the company to be
held.
The Sub-Advisor ensures that at least:• 90% of equity securities issued by large companies
domiciled in developed countries; and• 75% of equity securities issued by large companies
domiciled in Emerging Market Countries, or by small andmedium companies,
held by the Portfolio are rated against the abovemeasures. For the purposes of this test, small companies
are those with a market capitalisation below €5 billion,
medium companies are those between €5 billion and €10billion and large companies are those above €10 billion.
To support and enhance the promotion of environmental
and social characteristics, the Sub-Advisor will seek
proactive engagement with companies with a view toinfluencing management teams to improve theirpractices, for example on issues relating to carbon
emissions.
Further information on the Portfolio investment
guidelines, including the Columbia Threadneedle ESG
Materiality Rating methodology and engagement policy isavailable at columbiathreadneedle.com.
The Portfolio is categorised as one that promotes
environmental or social characteristics under Article 8 of
the EU Regulation 2019/2088 on sustainability-related

6

Details after Significant Event
Deviations from the index, including guidance on thelevel of risk relative to the index, will be considered aspart of the Sub-Advisor’s risk monitoring process.
Promotion of Environmental and Social
Characteristics
The Sub-Advisor promotes environmental and social
characteristics by integrating a range of responsible
investment measures into the investment decisionmaking process, as well as ensuring that the companies
in which the Portfolio invests follow good governancepractices.
Information about the environmental or social
characteristics promoted by the Portfolio and theirintegration into the investment process is available in the
SFDR RTS Annex of the Prospectus.

Details of Significant Events
Columbia Threadneedle (Lux) I; Columbia Threadneedle (Lux) II

Columbia Threadneedle (Lux) I
Portfolio Name

Date of
Significant Details before Significant Event
Event

Details after Significant Event

disclosures in the financial services sector (SFDR).

01/12/2021

Investment objective and policy change:

Investment objective and policy change:

The American Smaller Companies Portfolio seeks toachieve capital appreciation by investing principally inshares issued by American Smaller Companies that are
domiciled in the United States or have significant US
operations.

The American Smaller Companies Portfolio seeks toachieve capital appreciation by investing principally inshares issued by American Smaller Companies that are
domiciled in the United States or have significant US
operations.

The Portfolio may use financial derivative instruments for The Portfolio may use financial derivative instruments
for hedging purposes.
hedging purposes.
The Portfolio is actively managed in reference to theRussell 2500 Index. The index is broadly representativeof the companies in which the Portfolio invests, andprovides a suitable target benchmark against which
Portfolio performance will be measured and evaluatedover time. The Sub-Advisor has discretion to selectinvestments with weightings different to the index, andthat are not in the index, and the Portfolio may display
significant divergence from the index.
Deviations from the index, including guidance on thelevel of risk relative to the index, will be considered aspart of the Sub-Advisor’s risk monitoring process, toensure the overall level of risk is broadly consistent with
the index. In line with its active management strategy,
there may be significant deviation from the index.

The Portfolio is actively managed in reference to theRussell 2500 Index. The index is broadly
representative of the companies in which the Portfolio
invests, and provides a suitable target benchmark
against which Portfolio performance will be measured
and evaluated over time. The Portfolio promotes
environmental and social characteristics by aiming tocompare favourably against the index over rolling 12month periods when assessed according to the
Columbia Threadneedle ESG Materiality Rating, as set
out below. The index is not designed to specificallyconsider environmental or social characteristics. The
Sub-Advisor has discretion to select investments withweightings different to the index, and that are not in theindex, and the Portfolio may display significant
divergence from the index.
Deviations from the index, including guidance on thelevel of risk relative to the index, will be considered aspart of the Sub-Advisor’s risk monitoring process, toensure the overall level of risk is broadly consistent with
the index. In line with its active management strategy,
there may be significant deviation from the index.
Promotion of Environmental and Social
Characteristics
The Sub-Advisor promotes environmental and social
characteristics by integrating a range of responsible
investment measures into the investment decisionmaking process.
Over rolling 12-month periods, the Portfolio aims tocompare favourably with the Russell 2500 Index
according to the Columbia Threadneedle ESG
Materiality Rating - a proprietary model which builds on
the Sustainability and Accounting Standards Board(SASB®) framework. This model identifies material
environmental, social and governance (“ESG”) factors
across a broad range of sectors, and provides aninsight into the management focus and standards ofoperating practices of a company. The Sub-Advisor
considers that companies that manage ESG risks
effectively are better positioned to address futurechallenges, and capitalise on unknown and known
future business opportunities. Companies that lead on
the most material ESG metrics should be well
positioned to build competitive advantage and sustain
their long-term future.

7

The Portfolio also aims to exclude companies thatbreach accepted international standards and principles

Details of Significant Events
Columbia Threadneedle (Lux) I; Columbia Threadneedle (Lux) II

Columbia Threadneedle (Lux) I
Portfolio Name

Date of
Significant Details before Significant Event
Event

Details after Significant Event(e.g. the United Nations Global Compact). Companies
in breach may be assessed as suitable for investmentby the Portfolio, if in the opinion of the Sub-Advisor
there are tangible mitigating factors for the company to
be held.
The Sub-Advisor ensures that at least:• 90% of equity securities issued by large companies
domiciled in developed countries; and• 75% of equity securities issued by large companies
domiciled in Emerging Market Countries, or by small
and medium companies,
held by the Portfolio are rated against the abovemeasures. For the purposes of this test, small
companies are those with a market capitalisation below€5 billion, medium companies are those between €5billion and €10 billion and large companies are thoseabove €10 billion.
To support and enhance the promotion ofenvironmental and social characteristics, the SubAdvisor will seek proactive engagement with companies
with a view to influencing management teams to
improve their practices, for example on issues relating
to carbon emissions.
Further information on the Portfolio investment
guidelines, including the Columbia Threadneedle ESG
Materiality Rating methodology and engagement policy
is available at columbiathreadneedle.com.
The Portfolio is categorised as one that promotes
environmental or social characteristics under Article 8 of
the EU Regulation 2019/2088 on sustainability-related
disclosures in the financial services sector (SFDR).

02/09/2024

20/11/2023

20/11/2023
CT (Lux) Asia Equities

Change to minimum proportion of assets insustainable investments:

Change to minimum proportion of assets insustainable investments:

N/A - no minimum commitment to sustainable
investments.

10%

Name change:

Name change:

Threadneedle (Lux) – Asia Equities

CT (Lux) Asia Equities

Investment objective and policy change:

Investment objective and policy change:

The Asia Equities Portfolio seeks to achieve capital
appreciation by investing principally in the equity
securities of companies domiciled in Asia (excluding
Japan), or with significant operations in Asia (excluding
Japan), including through depositary receipts. The
Portfolio may invest up to 40% of its Net Asset Value in
China A-Shares through the China-Hong Kong Stock
Connect Programme.

The Asia Equities Portfolio seeks to achieve capital
appreciation by investing principally in the equity
securities of companies domiciled in Asia (excluding
Japan), or with significant operations in Asia (excluding
Japan), including through depositary receipts. The
Portfolio may invest up to 40% of its Net Asset Value in
China A-Shares through the China-Hong Kong Stock
Connect Programme.

Further information is available in the SFDR RTS Annexof the Prospectus.

The Portfolio may use financial derivative instruments for The Portfolio may use financial derivative instruments forhedging purposes.
hedging purposes.
The Portfolio is actively managed in reference to the
MSCI AC Asia Pacific ex Japan Index. The index isbroadly representative of the companies in which thePortfolio invests, and provides a suitable target

8

For the purposes of managing liquidity, the Portfolio may
hold ancillary liquid assets (i.e. bank deposits at sight),
and may also hold bank deposits, Money Market
Instruments or money market funds for treasuryDetails of Significant Events
Columbia Threadneedle (Lux) I; Columbia Threadneedle (Lux) II

Columbia Threadneedle (Lux) I
Portfolio Name

Date of
Significant Details before Significant Event
Eventbenchmark against which Portfolio performance will bemeasured and evaluated over time. The Portfolio
promotes environmental and social characteristics byaiming to compare favourably against the index overrolling 12-month periods when assessed according to the
Columbia Threadneedle ESG Materiality Rating, as set
out below. The index is not designed to specificallyconsider environmental or social characteristics. The
Sub-Advisor has discretion to select investments withweightings different to the index, and that are not in theindex, and the Portfolio may display significant
divergence from the index.
Deviations from the index, including guidance on thelevel of risk relative to the index, will be considered aspart of the Sub-Advisor’s risk monitoring process, toensure the overall level of risk is broadly consistent with
the index. In line with its active management strategy,
there may be significant deviation from the index.
Promotion of Environmental and Social
Characteristics
The Sub-Advisor promotes environmental and social
characteristics by integrating a range of responsible
investment measures into the investment decisionmaking process.
Over rolling 12-month periods, the Portfolio aims tocompare favourably with the MSCI AC Asia Pacific ex
Japan Index according to the Columbia Threadneedle
ESG Materiality Rating - a proprietary model which builds
on the Sustainability and Accounting Standards Board(SASB®) framework. This model identifies material
environmental, social and governance (“ESG”) factors
across a broad range of sectors, and provides an insight
into the management focus and standards of operating
practices of a company. The Sub-Advisor considers thatcompanies that manage ESG risks effectively are better
positioned to address future challenges, and capitaliseon unknown and known future business opportunities.
Companies that lead on the most material ESG metrics
should be well positioned to build competitive advantage
and sustain their long-term future.
The Portfolio also aims to exclude companies thatbreach accepted international standards and principles(e.g. the United Nations Global Compact). Companies inbreach may be assessed as suitable for investment by
the Portfolio, if in the opinion of the Sub-Advisor there
are tangible mitigating factors for the company to be
held.
The Sub-Advisor ensures that at least:• 90% of equity securities issued by large companies
domiciled in developed countries; and• 75% of equity securities issued by large companies
domiciled in Emerging Market Countries, or by small andmedium companies,
held by the Portfolio are rated against the abovemeasures. For the purposes of this test, small companies
are those with a market capitalisation below €5 billion,
medium companies are those between €5 billion and €10billion and large companies are those above €10 billion.

9

Details after Significant Event
purposes. In normal market conditions, investments inthese assets or instruments will not exceed 10% of thePortfolio’s Net Asset Value.
The Portfolio is actively managed in reference to the
MSCI AC Asia Pacific ex Japan Index. The index isbroadly representative of the companies in which thePortfolio invests, and provides a suitable target
benchmark against which Portfolio performance will bemeasured and evaluated over time. The index is notdesigned to specifically consider environmental or social
characteristics.
The Sub-Advisor has discretion to select investmentswith weightings different to the index, and that are not in
the index, and the Portfolio may display significant
divergence from the index.
Deviations from the index, including guidance on thelevel of risk relative to the index, will be considered aspart of the Sub-Advisor’s risk monitoring process.
Promotion of Environmental and Social
Characteristics
The Sub-Advisor promotes environmental and social
characteristics by integrating a range of responsible
investment measures into the investment decisionmaking process, as well as ensuring that the companies
in which the Portfolio invests follow good governancepractices.
Information about the environmental or social
characteristics promoted by the Portfolio and theirintegration into the investment process is available in the
SFDR RTS Annex of the Prospectus.

Details of Significant Events
Columbia Threadneedle (Lux) I; Columbia Threadneedle (Lux) II

Columbia Threadneedle (Lux) I
Portfolio Name

Date of
Significant Details before Significant Event
Event

Details after Significant Event

To support and enhance the promotion of environmental
and social characteristics, the Sub-Advisor will seek
proactive engagement with companies with a view toinfluencing management teams to improve theirpractices, for example on issues relating to carbon
emissions.
Further information on the Portfolio investment
guidelines, including the Columbia Threadneedle ESG
Materiality Rating methodology and engagement policy isavailable at columbiathreadneedle.com.
The Portfolio is categorised as one that promotes
environmental or social characteristics under Article 8 of
the EU Regulation 2019/2088 on sustainability-related
disclosures in the financial services sector (SFDR).
01/12/2021

Investment objective and policy change:

Investment objective and policy change:

The Asia Equities Portfolio seeks to achieve capital
appreciation by investing principally in the equity
securities of companies domiciled in Asia (excluding
Japan), or with significant operations in Asia (excluding
Japan), including through depositary receipts. The
Portfolio may invest up to 40% of its Net Asset Value in
China A-Shares through the China-Hong Kong Stock
Connect Programme.

The Asia Equities Portfolio seeks to achieve capital
appreciation by investing principally in the equity
securities of companies domiciled in Asia (excluding
Japan), or with significant operations in Asia (excluding
Japan), including through depositary receipts. The
Portfolio may invest up to 40% of its Net Asset Value in
China A-Shares through the China-Hong Kong Stock
Connect Programme.

The Portfolio may use financial derivative instruments for The Portfolio may use financial derivative instruments
for hedging purposes.
hedging purposes.
The Portfolio is actively managed in reference to the
MSCI AC Asia Pacific ex Japan Index. The index isbroadly representative of the companies in which thePortfolio invests, and provides a suitable target
benchmark against which Portfolio performance will bemeasured and evaluated over time. The Sub-Advisor
has discretion to select investments with weightings
different to the index, and that are not in the index, and
the Portfolio may display significant divergence from theindex..
Deviations from the index, including guidance on thelevel of risk relative to the index, will be considered aspart of the Sub-Advisor’s risk monitoring process, toensure the overall level of risk is broadly consistent with
the index. In line with its active management strategy,
there may be significant deviation from the index.

The Portfolio is actively managed in reference to the
MSCI AC Asia Pacific ex Japan Index. The index isbroadly representative of the companies in which thePortfolio invests, and provides a suitable target
benchmark against which Portfolio performance will bemeasured and evaluated over time. The Portfolio
promotes environmental and social characteristics byaiming to compare favourably against the index overrolling 12-month periods when assessed according to
the Columbia Threadneedle ESG Materiality Rating, as
set out below. The index is not designed to specificallyconsider environmental or social characteristics. The
Sub-Advisor has discretion to select investments withweightings different to the index, and that are not in theindex, and the Portfolio may display significant
divergence from the index.
Deviations from the index, including guidance on thelevel of risk relative to the index, will be considered aspart of the Sub-Advisor’s risk monitoring process, toensure the overall level of risk is broadly consistent with
the index. In line with its active management strategy,
there may be significant deviation from the index.
Promotion of Environmental and Social
Characteristics
The Sub-Advisor promotes environmental and social
characteristics by integrating a range of responsible
investment measures into the investment decisionmaking process.
Over rolling 12-month periods, the Portfolio aims tocompare favourably with the MSCI AC Asia Pacific ex
Japan Index according to the Columbia Threadneedle10Details of Significant Events
Columbia Threadneedle (Lux) I; Columbia Threadneedle (Lux) II

Columbia Threadneedle (Lux) I
Portfolio Name

Date of
Significant Details before Significant Event
Event

Details after Significant Event
ESG Materiality Rating - a proprietary model whichbuilds on the Sustainability and Accounting Standards
Board (SASB®) framework. This model identifies
material environmental, social and governance (“ESG”)
factors across a broad range of sectors, and provides
an insight into the management focus and standards ofoperating practices of a company. The Sub-Advisor
considers that companies that manage ESG risks
effectively are better positioned to address futurechallenges, and capitalise on unknown and known
future business opportunities. Companies that lead on
the most material ESG metrics should be well
positioned to build competitive advantage and sustain
their long-term future.
The Portfolio also aims to exclude companies thatbreach accepted international standards and principles(e.g. the United Nations Global Compact). Companies
in breach may be assessed as suitable for investmentby the Portfolio, if in the opinion of the Sub-Advisor
there are tangible mitigating factors for the company to
be held.
The Sub-Advisor ensures that at least:• 90% of equity securities issued by large companies
domiciled in developed countries; and• 75% of equity securities issued by large companies
domiciled in Emerging Market Countries, or by small
and medium companies,
held by the Portfolio are rated against the abovemeasures. For the purposes of this test, small
companies are those with a market capitalisation below€5 billion, medium companies are those between €5billion and €10 billion and large companies are thoseabove €10 billion.
To support and enhance the promotion ofenvironmental and social characteristics, the SubAdvisor will seek proactive engagement with companies
with a view to influencing management teams to
improve their practices, for example on issues relating
to carbon emissions.
Further information on the Portfolio investment
guidelines, including the Columbia Threadneedle ESG
Materiality Rating methodology and engagement policy
is available at columbiathreadneedle.com.
The Portfolio is categorised as one that promotes
environmental or social characteristics under Article 8 of
the EU Regulation 2019/2088 on sustainability-related
disclosures in the financial services sector (SFDR).

20/11/2023

CT (Lux) Asian Equity Income

01/02/2013

01/02/2013

Name change:

Name change:

Threadneedle (Lux) – Asian Equity Income

CT (Lux) Asian Equity Income

Name change:

Name change:

Threadneedle (Lux) – Asia

Threadneedle (Lux) – Asian Equity Income

Investment objective and policy change:

Investment objective and policy change:

The Asia Portfolio seeks to achieve capital appreciation
by investing principally in the equity securities of

The Asian Equity Income Portfolio seeks to achieve
income and capital appreciation by investing principally11

Details of Significant Events
Columbia Threadneedle (Lux) I; Columbia Threadneedle (Lux) II

Columbia Threadneedle (Lux) I
Portfolio Name

Date of
Significant Details before Significant Event
Event

20/11/2023

01/09/2021
CT (Lux) Credit Opportunities
01/03/2019

20/11/2023
CT (Lux) Emerging Market
Corporate Bonds

CT (Lux) Emerging Market Debt

CT (Lux) Enhanced Commodities

Details after Significant Eventcompanies domiciled in Asia (with the exclusion of Japan)
or with significant Asian (excluding Japan) operations.
The Portfolio may further invest in other securities(including fixed income securities, other equities andMoney Market Instruments).

in the equity securities of companies domiciled in Asia(with the exclusion of Japan) or with significant Asian(excluding Japan) operations. The Portfolio may further
invest in other securities (including fixed income
securities, other equities, convertible debt securities,
real estate investment trusts and Money Market
Instruments).

Name change:

Name change:

Threadneedle (Lux) – Credit Opportunities

CT (Lux) Credit Opportunities

Benchmark change:

Benchmark change:

ICE BofA Euro Currency 1-Month Deposit Bid Rate
Constant Maturity Index (Local Total Return)

Compounded euro short-term rate (€STR) average rate,
1 month tenor

Benchmark change:

Benchmark change:

Citigroup EUR 1 Month Eurodeposit

ICE BofA Euro Currency 1-Month Deposit Bid Rate
Constant Maturity Index (Local Total Return)

Name change:

Name change:

Threadneedle (Lux) – Emerging Market Corporate Bonds CT (Lux) Emerging Market Corporate Bonds
01/01/2013

20/11/2023

20/11/2023

02/09/2024

Benchmark change:

Benchmark change:

J.P. Morgan CEMBI Diversified Index

J.P. Morgan CEMBI Broad Diversified Index

Name change:

Name change:

Threadneedle (Lux) – Emerging Market Debt

CT (Lux) Emerging Market Debt

Name change:

Name change:

Threadneedle (Lux) – Enhanced Commodities

CT (Lux) Enhanced Commodities

Change to minimum proportion of assets insustainable investments:

Change to minimum proportion of assets insustainable investments:

5%20%Further information is available in the SFDR RTS Annexof the Prospectus.

20/11/2023

20/11/2023
CT (Lux) European Corporate Bond

Name change:

Name change:

Threadneedle (Lux) – European Corporate BondCT (Lux) European Corporate Bond

Investment objective and policy change:

Investment objective and policy change:

The European Corporate Bond Portfolio seeks to achievea total return from income and capital appreciation by
investing in fixed income securities that are primarily
denominated in Euro.

The European Corporate Bond Portfolio seeks toachieve a total return from income and capital
appreciation by investing in fixed income securities thatare primarily denominated in Euro.

The Portfolio will principally invest in a broad range ofInvestment Grade fixed income securities issued bycompanies domiciled in Europe or which have significant
European operations. It may also invest in Investment
Grade securities that are issued by sovereign andsupranational borrowers. However, it is intended that thePortfolio will not invest more than 25% of its net assets insecurities that are rated AAA (Standard & Poor’s) or anequivalent rating from another leading rating agency. A
maximum of 10% of the Portfolio’s net assets can be

The Portfolio will principally invest in a broad range ofInvestment Grade fixed income securities issued bycompanies domiciled in Europe or which havesignificant European operations. It may also invest in
Investment Grade securities that are issued bysovereign and supranational borrowers. However, it isintended that the Portfolio will not invest more than 25%
of its net assets in securities that are rated AAA(Standard & Poor’s) or an equivalent rating fromanother leading rating agency. A maximum of 10% of

12Details of Significant Events
Columbia Threadneedle (Lux) I; Columbia Threadneedle (Lux) II

Columbia Threadneedle (Lux) I
Portfolio Name

Date of
Significant Details before Significant Event
Event
invested in securities that are rated below Investment
Grade. The Portfolio may invest in mortgage and assetbacked securities (the mortgage and asset-backed
securities not exceeding 10% of the Portfolio’s Net Asset
Value) and CoCos (not exceeding 10% of the Portfolio’s
Net Asset Value).
Where securities are denominated in a currency otherthan Euro it is intended that they will typically be hedged
back into Euro.

Details after Significant Event
the Portfolio’s net assets can be invested in securities
that are rated below Investment Grade. The Portfolio
may invest in mortgage and asset-backed securities(the mortgage and asset-backed securities notexceeding 10% of the Portfolio’s Net Asset Value) and
CoCos (not exceeding 10% of the Portfolio’s Net Asset
Value).
Where securities are denominated in a currency otherthan Euro it is intended that they will typically behedged back into Euro.

The Portfolio may use financial derivative instruments forthe purpose of reducing risks or costs, i.e. where the use The Portfolio may use financial derivative instruments
for the purpose of reducing risks or costs, i.e. where theof a financial derivative instrument is economicallyuse of a financial derivative instrument is economicallyappropriate.
appropriate.
For the purposes of managing liquidity, the Portfolio may
For the purposes of managing liquidity, the Portfolio
hold ancillary liquid assets (i.e. bank deposit at sight),
and may hold bank deposits, money market instruments may hold ancillary liquid assets (i.e. bank deposits at
or money market funds for treasury purposes. In normal sight), and may also hold bank deposits, Money Market
market conditions, investments in ancillary liquid assets, Instruments or money market funds for treasury
purposes. In normal market conditions, investments inbank deposits, money market instruments or money
these assets or instruments will not exceed 10% of themarket funds will not exceed 10% of the Portfolio's net
Portfolio's Net Asset Value.
asset value.
The Portfolio is actively managed in reference to theiBoxx Euro Corporate Bond Index. The index is broadly
representative of the securities in which the Portfolio
invests, and provides a suitable target benchmark
against which Portfolio performance will be measured
and evaluated over time. The Sub-Advisor has
discretion to select investments with weightings different
to the index, and that are not in the index, and thePortfolio may display significant divergence from theindex.
Deviations from the index, including guidance on thelevel of risk relative to the index, will be considered aspart of the Sub Advisor’s risk monitoring process, toensure the overall level of risk is broadly consistent with
the index. In line with its active management strategy,
there may be significant deviation from the index.

The Portfolio is actively managed in reference to theiBoxx Euro Corporate Bond Index. The index is broadly
representative of the securities in which the Portfolio
invests, and provides a suitable target benchmark
against which Portfolio performance will be measured
and evaluated over time. The index is not designed to
specifically consider environmental or social
characteristics. The Sub-Advisor has discretion to
select investments with weightings different to theindex, and that are not in the index, and the Portfolio
may display significant divergence from the index.
Deviations from the index, including guidance on thelevel of risk relative to the index, will be considered aspart of the Sub Advisor’s risk monitoring process.
Promotion of Environmental and Social
Characteristics
The Sub-Advisor promotes environmental and social
characteristics by integrating a range of responsible
investment measures into the investment decisionmaking process, as well as ensuring that the companies
in which the Portfolio invests follow good governancepractices.
Information about the environmental or social
characteristics promoted by the Portfolio and theirintegration into the investment process is available in
the SFDR RTS Annex of the Prospectus.

02/09/2024

Change to minimum proportion of assets insustainable investments:

Change to minimum proportion of assets insustainable investments:

5%

20%

CT (Lux) European High Yield
Bond

Further information is available in the SFDR RTS Annexof the Prospectus.
20/11/2023

Name change:

Name change:

Threadneedle (Lux) – European High Yield BondCT (Lux) European High Yield Bond

13

Details of Significant Events
Columbia Threadneedle (Lux) I; Columbia Threadneedle (Lux) II

Columbia Threadneedle (Lux) I
Portfolio Name

Date of
Significant Details before Significant Event
Event
20/11/2023

Details after Significant Event

Investment objective and policy change:

Investment objective and policy change:

The European High Yield Bond Portfolio seeks toachieve a total return from income and capital
appreciation by investing principally in Euro or Sterling
denominated fixed income securities that are rated below
Investment Grade.

The European High Yield Bond Portfolio seeks toachieve a total return from income and capital
appreciation by investing principally in Euro or Sterling
denominated fixed income securities that are rated
below Investment Grade.

The Portfolio will principally invest in fixed income
securities issued by companies domiciled in Europe, orwith significant European operations.

The Portfolio will principally invest in fixed income
securities issued by companies domiciled in Europe, orwith significant European operations.

The Portfolio may invest in CoCos (not exceeding 10% of The Portfolio may invest in CoCos (not exceeding 10%
the Portfolio’s Net Asset Value).
of the Portfolio’s Net Asset Value).
Where securities are denominated in a currency otherthan Euro it is intended that they will typically be hedged
back into Euro.

Where securities are denominated in a currency otherthan Euro it is intended that they will typically be hedged
back into Euro.

The Portfolio may use financial derivative instruments forthe purpose of reducing risks or costs, i.e. where the useof a financial derivative instrument is economicallyappropriate.

The Portfolio may use financial derivative instruments forthe purpose of reducing risks or costs, i.e. where the useof a financial derivative instrument is economicallyappropriate.

The weighted average credit rating of the Portfolio is
The weighted average credit rating of the Portfolio is
expected to be between Ba2 and B2 as rated by Moody’s expected to be between Ba2 and B2 as rated by(or equivalent).
Moody’s (or equivalent).
The Portfolio is actively managed in reference to the ICE
BofA European Currency High Yield Excluding
Subordinated Financials Constrained Index. The index isbroadly representative of the securities in which thePortfolio invests, and provides a suitable target
benchmark against which Portfolio performance will bemeasured and evaluated over time. The Portfolio
promotes environmental and social characteristics byaiming to compare favourably against the index overrolling 12-month periods when assessed according to the
Columbia Threadneedle ESG Materiality Rating, as set
out below. The index is not designed to specificallyconsider environmental or social characteristics. The
Sub-Advisor has discretion to select investments withweightings different to the index, and that are not in theindex, and the Portfolio may display significant
divergence from the index.
Deviations from the index, including guidance on thelevel of risk relative to the index, will be considered aspart of the Sub-Advisor’s risk monitoring process, toensure the overall level of risk is broadly consistent with
the index. In line with its active management strategy,
there may be significant deviation from the index.
Promotion of Environmental and Social
Characteristics
The Sub-Advisor promotes environmental and social
characteristics by integrating a range of responsible
investment measures into the investment decisionmaking process.
Over rolling 12-month periods, the Portfolio aims tocompare favourably with the ICE BofA European
Currency High Yield Excluding Subordinated Financials
Constrained Index according to the Columbia
Threadneedle ESG Materiality Rating - a proprietarymodel which builds on the Sustainability and AccountingStandards Board (SASB®) framework. This model14

For the purposes of managing liquidity, the Portfolio may
hold ancillary liquid assets (i.e. bank deposits at sight),
and may also hold bank deposits, Money Market
Instruments or money market funds for treasury
purposes. In normal market conditions, investments inthese assets or instruments will not exceed 10% of thePortfolio's Net Asset Value.
The Portfolio is actively managed in reference to the ICE
BofA European Currency High Yield Excluding
Subordinated Financials Constrained Index. The index isbroadly representative of the securities in which thePortfolio invests, and provides a suitable target
benchmark against which Portfolio performance will bemeasured and evaluated over time. The index is notdesigned to specifically consider environmental or social
characteristics.
The Sub-Advisor has discretion to select investmentswith weightings different to the index, and that are not in
the index, and the Portfolio may display significant
divergence from the index.
Deviations from the index, including guidance on thelevel of risk relative to the index, will be considered aspart of the Sub-Advisor’s risk monitoring process.
Promotion of Environmental and Social
Characteristics
The Sub-Advisor promotes environmental and social
characteristics by integrating a range of responsible
investment measures into the investment decisionmaking process, as well as ensuring that the companies
in which the Portfolio invests follow good governancepractices.
Information about the environmental or social
characteristics promoted by the Portfolio and theirintegration into the investment process is available in the
SFDR RTS Annex of the Prospectus.

Details of Significant Events
Columbia Threadneedle (Lux) I; Columbia Threadneedle (Lux) II

Columbia Threadneedle (Lux) I
Portfolio Name

Date of
Significant Details before Significant Event
Event

Details after Significant Event

identifies material environmental, social and governance(“ESG”) factors across a broad range of sectors, andprovides an insight into the management focus andstandards of operating practices of a company. The SubAdvisor considers that companies that manage ESG
risks effectively are better positioned to address futurechallenges, and capitalise on unknown and known futurebusiness opportunities. Companies that lead on the mostmaterial ESG metrics should be well positioned to build
competitive advantage and sustain their long-term future.
The Portfolio also aims to exclude companies thatbreach accepted international standards and principles(e.g. the United Nations Global Compact). Companies inbreach may be assessed as suitable for investment by
the Portfolio, if in the opinion of the Sub-Advisor there
are tangible mitigating factors for the company to be
held.
The Sub-Advisor ensures that at least two thirds of the
fixed income securities held by the Portfolio are rated
against the above measures.
To support and enhance the promotion of environmental
and social characteristics, the Sub-Advisor will seek
proactive engagement with companies with a view toinfluencing management teams to improve theirpractices, for example on issues relating to carbon
emissions.
Further information on the Portfolio investment
guidelines, including the Columbia Threadneedle ESG
Materiality Rating methodology and engagement policy isavailable at columbiathreadneedle.com.
The Portfolio is categorised as one that promotes
environmental or social characteristics under Article 8 of
the EU Regulation 2019/2088 on sustainability-related
disclosures in the financial services sector (SFDR).
01/12/2021

Investment objective and policy change:

Investment objective and policy change:

The European High Yield Bond Portfolio seeks toachieve a total return from income and capital
appreciation by investing principally in Euro or Sterling
denominated fixed income securities that are rated below
Investment Grade.

The European High Yield Bond Portfolio seeks toachieve a total return from income and capital
appreciation by investing principally in Euro or Sterling
denominated fixed income securities that are rated
below Investment Grade.

The Portfolio will principally invest in fixed income
securities issued by companies domiciled in Europe, orwith significant European operations.

The Portfolio will principally invest in fixed income
securities issued by companies domiciled in Europe, orwith significant European operations.

The Portfolio may invest in CoCos (not exceeding 10% of The Portfolio may invest in CoCos (not exceeding 10%
the Portfolio’s Net Asset Value).
of the Portfolio’s Net Asset Value).
Where securities are denominated in a currency otherthan Euro it is intended that they will typically be hedged
back into Euro.

Where securities are denominated in a currency otherthan Euro it is intended that they will typically behedged back into Euro.

The Portfolio may use financial derivative instruments forthe purpose of reducing risks or costs, i.e. where the useof a financial derivative instrument is economicallyappropriate.

The Portfolio may use financial derivative instruments
for the purpose of reducing risks or costs, i.e. where theuse of a financial derivative instrument is economicallyappropriate.

The weighted average credit rating of the Portfolio is
The weighted average credit rating of the Portfolio is
expected to be between Ba2 and B2 as rated by Moody’s expected to be between Ba2 and B2 as rated by(or equivalent).
Moody’s (or equivalent).

15

Details of Significant Events
Columbia Threadneedle (Lux) I; Columbia Threadneedle (Lux) II

Columbia Threadneedle (Lux) I
Portfolio Name

Date of
Significant Details before Significant Event
Event
The Portfolio is actively managed in reference to the ICE
BofA European Currency High Yield Excluding
Subordinated Financials Constrained Index. The index isbroadly representative of the securities in which thePortfolio invests, and provides a suitable target
benchmark against which Portfolio performance will bemeasured and evaluated over time. The Sub-Advisor
has discretion to select investments with weightings
different to the index, and that are not in the index, and
the Portfolio may display significant divergence from theindex.
Deviations from the index, including guidance on thelevel of risk relative to the index, will be considered aspart of the Sub-Advisor’s risk monitoring process, toensure the overall level of risk is broadly consistent with
the index. In line with its active management strategy,
there may be significant deviation from the index.

Details after Significant Event
The Portfolio is actively managed in reference to the
ICE BofA European Currency High Yield Excluding
Subordinated Financials Constrained Index. The index
is broadly representative of the securities in which thePortfolio invests, and provides a suitable target
benchmark against which Portfolio performance will bemeasured and evaluated over time. The Portfolio
promotes environmental and social characteristics byaiming to compare favourably against the index overrolling 12-month periods when assessed according to
the Columbia Threadneedle ESG Materiality Rating, as
set out below. The index is not designed to specificallyconsider environmental or social characteristics. The
Sub-Advisor has discretion to select investments withweightings different to the index, and that are not in theindex, and the Portfolio may display significant
divergence from the index.
Deviations from the index, including guidance on thelevel of risk relative to the index, will be considered aspart of the Sub-Advisor’s risk monitoring process, toensure the overall level of risk is broadly consistent with
the index. In line with its active management strategy,
there may be significant deviation from the index.
Promotion of Environmental and Social
Characteristics
The Sub-Advisor promotes environmental and social
characteristics by integrating a range of responsible
investment measures into the investment decisionmaking process.
Over rolling 12-month periods, the Portfolio aims tocompare favourably with the ICE BofA European
Currency High Yield Excluding Subordinated Financials
Constrained Index according to the Columbia
Threadneedle ESG Materiality Rating - a proprietarymodel which builds on the Sustainability andAccounting Standards Board (SASB®) framework. Thismodel identifies material environmental, social andgovernance (“ESG”) factors across a broad range ofsectors, and provides an insight into the management
focus and standards of operating practices of acompany. The Sub-Advisor considers that companies
that manage ESG risks effectively are better positioned
to address future challenges, and capitalise on
unknown and known future business opportunities.
Companies that lead on the most material ESG metrics
should be well positioned to build competitive
advantage and sustain their long-term future.
The Portfolio also aims to exclude companies thatbreach accepted international standards and principles(e.g. the United Nations Global Compact). Companies
in breach may be assessed as suitable for investmentby the Portfolio, if in the opinion of the Sub-Advisor
there are tangible mitigating factors for the company to
be held.
The Sub-Advisor ensures that at least two thirds of the
fixed income securities held by the Portfolio are rated
against the above measures.
To support and enhance the promotion of

16

Details of Significant Events
Columbia Threadneedle (Lux) I; Columbia Threadneedle (Lux) II

Columbia Threadneedle (Lux) I
Portfolio Name

Date of
Significant Details before Significant Event
Event

Details after Significant Eventenvironmental and social characteristics, the SubAdvisor will seek proactive engagement with companies
with a view to influencing management teams to
improve their practices, for example on issues relating
to carbon emissions.
Further information on the Portfolio investment
guidelines, including the Columbia Threadneedle ESG
Materiality Rating methodology and engagement policy
is available at columbiathreadneedle.com.
The Portfolio is categorised as one that promotes
environmental or social characteristics under Article 8 of
the EU Regulation 2019/2088 on sustainability-related
disclosures in the financial services sector (SFDR).

02/09/2024

Change to minimum proportion of assets insustainable investments:

Change to minimum proportion of assets insustainable investments:

5%20%Further information is available in the SFDR RTS Annexof the Prospectus.

20/11/2023

20/11/2023

CT (Lux) European SelectName change:

Name change:

Threadneedle (Lux) – European SelectCT (Lux) European SelectInvestment objective and policy change:

Investment objective and policy change:

The European Select Portfolio seeks to achieve capital
appreciation by investing principally in the equity
securities of companies domiciled in Continental Europe
or which have significant Continental European
operations. These may include large, medium andsmaller companies. There will be no particularspecialisation. The select investment approach meansthat the Portfolio has the flexibility to take significant
stock and sector positions which may lead to increased
levels of volatility. The Portfolio may further invest inother securities (including fixed income securities, other
equities and Money Market Instruments).

The European Select Portfolio seeks to achieve capital
appreciation by investing principally in the equity
securities of companies domiciled in Continental Europe
or which have significant Continental European
operations. These may include large, medium andsmaller companies. There will be no particularspecialisation. The select investment approach meansthat the Portfolio has the flexibility to take significant
stock and sector positions which may lead to increased
levels of volatility. The Portfolio may further invest inother securities (including fixed income securities, other
equities and Money Market Instruments).

The Portfolio is actively managed in reference to the
FTSE World Europe ex UK Index. The index is broadly
representative of the companies in which the Portfolio
invests, and provides a suitable target benchmark
against which Portfolio performance will be measured
and evaluated over time. The Portfolio promotes
environmental and social characteristics by aiming tocompare favourably against the index over rolling 12month periods when assessed according to the
Columbia Threadneedle ESG Materiality Rating, as set
out below. The index is not designed to specificallyconsider environmental or social characteristics. The
Sub-Advisor has discretion to select investments withweightings different to the index, and that are not in theindex, and the Portfolio may display significant
divergence from the index.

For the purposes of managing liquidity, the Portfolio may
hold ancillary liquid assets (i.e. bank deposits at sight),
and may also hold bank deposits, Money Market
Instruments or money market funds for treasury
purposes. In normal market conditions, investments inthese assets or instruments will not exceed 10% of thePortfolio's Net Asset Value.

Deviations from the index, including guidance on thelevel of risk relative to the index, will be considered aspart of the Sub-Advisor’s risk monitoring process, toensure the overall level of risk is broadly consistent with
the index. In line with its active management strategy,
there may be significant deviation from the17

The Portfolio is actively managed in reference to the
FTSE World Europe ex UK Index. The index is broadly
representative of the companies in which the Portfolio
invests, and provides a suitable target benchmark
against which Portfolio performance will be measured
and evaluated over time. The index is not designed to
specifically consider environmental or social
characteristics.
The Sub-Advisor has discretion to select investmentswith weightings different to the index, and that are not in
the index, and the Portfolio may display significant
divergence from the index.
Deviations from the index, including guidance on thelevel of risk relative to the index, will be considered as

Details of Significant Events
Columbia Threadneedle (Lux) I; Columbia Threadneedle (Lux) II

Columbia Threadneedle (Lux) I
Portfolio Name

Date of
Significant Details before Significant Event
Event
index.Deviations from the index, including guidance on
the level of risk relative to the index, will be consideredas part of the Sub-Advisor’s risk monitoring process, toensure the overall level of risk is broadly consistent with
the index. In line with its active management strategy,
there may be significant deviation from the index.
Promotion of Environmental and Social
Characteristics
The Sub-Advisor promotes environmental and social
characteristics by integrating a range of responsible
investment measures into the investment decisionmaking process.
Over rolling 12-month periods, the Portfolio aims tocompare favourably with the FTSE World Europe ex UK
Index according to the Columbia Threadneedle ESG
Materiality Rating - a proprietary model which builds on
the Sustainability and Accounting Standards Board(SASB®) framework. This model identifies material
environmental, social and governance (“ESG”) factors
across a broad range of sectors, and provides an insight
into the management focus and standards of operating
practices of a company. The Sub-Advisor considers thatcompanies that manage ESG risks effectively are better
positioned to address future challenges, and capitaliseon unknown and known future business opportunities.
Companies that lead on the most material ESG metrics
should be well positioned to build competitive advantage
and sustain their long-term future.
The Portfolio also aims to exclude companies thatbreach accepted international standards and principles(e.g. the United Nations Global Compact). Companies inbreach may be assessed as suitable for investment by
the Portfolio, if in the opinion of the Sub-Advisor there
are tangible mitigating factors for the company to be
held.
The Sub-Advisor ensures that at least:• 90% of equity securities issued by large companies
domiciled in developed countries; and• 75% of equity securities issued by large companies
domiciled in Emerging Market Countries, or by small andmedium companies,
held by the Portfolio are rated against the abovemeasures. For the purposes of this test, small companies
are those with a market capitalisation below €5 billion,
medium companies are those between €5 billion and €10billion and large companies are those above €10 billion.
To support and enhance the promotion of environmental
and social characteristics, the Sub-Advisor will seek
proactive engagement with companies with a view toinfluencing management teams to improve theirpractices, for example on issues relating to carbon
emissions.
Further information on the Portfolio investment
guidelines, including the Columbia Threadneedle ESG
Materiality Rating methodology and engagement policy isavailable at columbiathreadneedle.com.
The Portfolio is categorised as one that promotes

18

Details after Significant Event
part of the Sub-Advisor’s risk monitoring process.
Promotion of Environmental and Social
Characteristics
The Sub-Advisor promotes environmental and social
characteristics by integrating a range of responsible
investment measures into the investment decisionmaking process, as well as ensuring that the companies
in which the Portfolio invests follow good governancepractices.
Information about the environmental or social
characteristics promoted by the Portfolio and theirintegration into the investment process is available in the
SFDR RTS Annex of this Prospectus.

Details of Significant Events
Columbia Threadneedle (Lux) I; Columbia Threadneedle (Lux) II

Columbia Threadneedle (Lux) I
Portfolio Name

Date of
Significant Details before Significant Event
Event

Details after Significant Eventenvironmental or social characteristics under Article 8 of
the EU Regulation 2019/2088 on sustainability-related
disclosures in the financial services sector (SFDR).
01/12/2021

Investment objective and policy change:

Investment objective and policy change:

The European Select Portfolio seeks to achieve capital
appreciation by investing principally in the equity
securities of companies domiciled in Continental Europe
or which have significant Continental European
operations. These may include large, medium andsmaller companies. There will be no particularspecialisation. The select investment approach meansthat the Portfolio has the flexibility to take significant
stock and sector positions which may lead to increased
levels of volatility. The Portfolio may further invest inother securities (including fixed income securities, other
equities and Money Market Instruments).

The European Select Portfolio seeks to achieve capital
appreciation by investing principally in the equity
securities of companies domiciled in Continental
Europe or which have significant Continental European
operations. These may include large, medium andsmaller companies. There will be no particularspecialisation. The select investment approach meansthat the Portfolio has the flexibility to take significant
stock and sector positions which may lead to increased
levels of volatility. The Portfolio may further invest inother securities (including fixed income securities, other
equities and Money Market Instruments).

The Portfolio is actively managed in reference to the
FTSE World Europe ex UK Index. The index is broadly
representative of the companies in which the Portfolio
invests, and provides a suitable target benchmark
against which Portfolio performance will be measured
and evaluated over time. The Sub-Advisor has
discretion to select investments with weightings different
to the index, and that are not in the index, and thePortfolio may display significant divergence from theindex.

The Portfolio is actively managed in reference to the
FTSE World Europe ex UK Index. The index is broadly
representative of the companies in which the Portfolio
invests, and provides a suitable target benchmark
against which Portfolio performance will be measured
and evaluated over time. The Portfolio promotes
environmental and social characteristics by aiming tocompare favourably against the index over rolling 12month periods when assessed according to the
Columbia Threadneedle ESG Materiality Rating, as set
out below. The index is not designed to specificallyconsider environmental or social characteristics. The
Sub-Advisor has discretion to select investments withweightings different to the index, and that are not in theindex, and the Portfolio may display significant
divergence from the index.

Deviations from the index, including guidance on thelevel of risk relative to the index, will be considered aspart of the Sub-Advisor’s risk monitoring process, toensure the overall level of risk is broadly consistent with
the index. In line with its active management strategy,
there may be significant deviation from the index.

Deviations from the index, including guidance on thelevel of risk relative to the index, will be considered aspart of the Sub-Advisor’s risk monitoring process, toensure the overall level of risk is broadly consistent with
the index. In line with its active management strategy,
there may be significant deviation from theindex.Deviations from the index, including guidance on
the level of risk relative to the index, will be consideredas part of the Sub-Advisor’s risk monitoring process, toensure the overall level of risk is broadly consistent with
the index. In line with its active management strategy,
there may be significant deviation from the index.
Promotion of Environmental and Social
Characteristics
The Sub-Advisor promotes environmental and social
characteristics by integrating a range of responsible
investment measures into the investment decisionmaking process.
Over rolling 12-month periods, the Portfolio aims tocompare favourably with the FTSE World Europe ex UK
Index according to the Columbia Threadneedle ESG
Materiality Rating - a proprietary model which builds on
the Sustainability and Accounting Standards Board(SASB®) framework. This model identifies material
environmental, social and governance (“ESG”) factors
across a broad range of sectors, and provides an

19

Details of Significant Events
Columbia Threadneedle (Lux) I; Columbia Threadneedle (Lux) II

Columbia Threadneedle (Lux) I
Portfolio Name

Date of
Significant Details before Significant Event
Event

Details after Significant Event
insight into the management focus and standards ofoperating practices of a company. The Sub-Advisor
considers that companies that manage ESG risks
effectively are better positioned to address futurechallenges, and capitalise on unknown and known
future business opportunities. Companies that lead on
the most material ESG metrics should be well
positioned to build competitive advantage and sustain
their long-term future.
The Portfolio also aims to exclude companies thatbreach accepted international standards and principles(e.g. the United Nations Global Compact). Companies
in breach may be assessed as suitable for investmentby the Portfolio, if in the opinion of the Sub-Advisor
there are tangible mitigating factors for the company to
be held.
The Sub-Advisor ensures that at least:• 90% of equity securities issued by large companies
domiciled in developed countries; and• 75% of equity securities issued by large companies
domiciled in Emerging Market Countries, or by small
and medium companies,
held by the Portfolio are rated against the abovemeasures. For the purposes of this test, small
companies are those with a market capitalisation below€5 billion, medium companies are those between €5billion and €10 billion and large companies are thoseabove €10 billion.
To support and enhance the promotion ofenvironmental and social characteristics, the SubAdvisor will seek proactive engagement with companies
with a view to influencing management teams to
improve their practices, for example on issues relating
to carbon emissions.
Further information on the Portfolio investment
guidelines, including the Columbia Threadneedle ESG
Materiality Rating methodology and engagement policy
is available at columbiathreadneedle.com.
The Portfolio is categorised as one that promotes
environmental or social characteristics under Article 8 of
the EU Regulation 2019/2088 on sustainability-related
disclosures in the financial services sector (SFDR).

29/11/2013

29/11/2013

Name change:

Name change:

Threadneedle (Lux) – European Absolute Alpha

Threadneedle (Lux) – European SelectInvestment objective and policy change:

Investment objective and policy change:

The European Absolute Alpha Portfolio seeks toachieve an absolute return.

The European Select Portfolio seeks to achieve capital
appreciation by investing principally in the equity
securities of companies domiciled in Continental
The Portfolio will principally invest in equity securities,
Europe or which have significant Continental European
convertible debt securities and equity related derivative
operations. These may include large, medium andinstruments of European companies headquartered or
smaller companies. There will be no particularexercising a predominant part of their activity in Europe,
specialisation. The select investment approach means
and when determined appropriate, cash and Moneythat the Portfolio has the flexibility to take significant
Market Instruments. Secondarily, the Portfolio may
invest in securities and derivatives related to companies stock and sector positions which may lead to increased
levels of volatility. The Portfolio may further invest in
headquartered outside Europe.

20

Details of Significant Events
Columbia Threadneedle (Lux) I; Columbia Threadneedle (Lux) II

Columbia Threadneedle (Lux) I
Portfolio Name

Date of
Significant Details before Significant Event
Event
The Portfolio will take both long and short positions (thePortfolio’s positions are generally expected to be
directionally long, but at times may be market neutral ornet short). Short positions (and possibly long positions)will be taken by the use of financial derivative
instruments to include, but not limited to, equity swaps,
total/excess return swaps, and futures and options
related to individual equity securities, related to
exchange traded funds and/or related to indices.

Details after Significant Eventother securities (including fixed income securities,
other equities and Money Market Instruments).

Hedging may also be achieved through the purchase of
exchange traded funds.
The Portfolio will use financial derivative instruments forinvestment purposes, hedging and efficient portfolio
management. The use of derivatives for investment
purposes may increase the risk profile of the Portfolio.
CT (Lux) European Short-Term
High Yield Bond

20/11/2023

02/09/2024

Name change:

Name change:

Threadneedle (Lux) – European Short-Term High Yield
Bond

CT (Lux) European Short-Term High Yield Bond

Change to minimum proportion of assets insustainable investments:

Change to minimum proportion of assets insustainable investments:

5%20%Further information is available in the SFDR RTS Annexof the Prospectus.

02/09/2024

Investment objective and policy change:

Investment objective and policy change:

The European Smaller Companies Portfolio seeks toachieve capital appreciation by investing principally in theequity securities of European Smaller Companies(excluding the United Kingdom). For this Portfolio,
European Smaller Companies are companies that are notrepresented in the top 225 companies in the FTSE World
Europe ex UK Index at the time of purchase.

The European Smaller Companies Portfolio seeks toachieve capital appreciation by investing principally inthe equity securities of European smaller companies(excluding the United Kingdom). For this Portfolio,
European smaller companies are companies arecompanies, that at the time of purchase, are no larger by
free-float adjusted market capitalisation1 than the largest
constituent of the MSCI Europe ex UK Small Cap Index.

The Portfolio may use financial derivative instruments forhedging purposes.
CT (Lux) European Smaller
Companies

For the purposes of managing liquidity, the Portfolio may
hold ancillary liquid assets (i.e. bank deposits at sight),
and may also hold bank deposits, Money Market
Instruments or money market funds for treasury purposes.
In normal market conditions, investments in these assets
or instruments will not exceed 10% of the Portfolio's Net
Asset Value.
The Portfolio is actively managed in reference to the
MSCI Europe ex UK Small Cap Index. The index isbroadly representative of the companies in which thePortfolio invests, and provides a suitable target
benchmark against which Portfolio performance will bemeasured and evaluated over time. The index is notdesigned to specifically consider environmental or social
characteristics.

The Portfolio may use financial derivative instruments forhedging purposes.
For the purposes of managing liquidity, the Portfolio may
hold ancillary liquid assets (i.e. bank deposits at sight),
as described under “Investment Restrictions” inAppendix A of the Prospectus.
The Portfolio may also hold bank deposits (other thanbank deposits at sight), Money Market Instruments ormoney market funds for treasury purposes. In normal
market conditions, investments in these assets or
instruments will not exceed 10% of the Portfolio's Net
Asset Value.

The Portfolio is actively managed in reference to the
MSCI Europe ex UK Small Cap Index. The index isbroadly representative of the companies in which thePortfolio invests, and provides a suitable target
The Sub-Advisor has discretion to select investments with benchmark against which Portfolio performance will beweightings different to the index, and that are not in themeasured and evaluated over time. The index is notindex, and the Portfolio may display significant divergence designed to specifically consider environmental or socialfrom the index.
characteristics.
Deviations from the index, including guidance on the level

21

The Investment Manager has discretion to selectDetails of Significant Events
Columbia Threadneedle (Lux) I; Columbia Threadneedle (Lux) II

Columbia Threadneedle (Lux) I
Portfolio Name

Date of
Significant Details before Significant Event
Eventof risk relative to the index, will be considered as part of
the Sub-Advisor’s risk monitoring process.
Promotion of Environmental and Social
Characteristics
The Sub-Advisor promotes environmental and social
characteristics by integrating a range of responsible
investment measures into the investment decision-making
process, as well as ensuring that the companies in which
the Portfolio invests follow good governance practices.
Information about the environmental or social
characteristics promoted by the Portfolio and theirintegration into the investment process is available in the
SFDR RTS Annex of the Prospectus.

Details after Significant Eventinvestments with weightings different to the index, andthat are not in the index, and the Portfolio may display
significant divergence from the index.
Deviations from the index, including guidance on thelevel of risk relative to the index, will be considered aspart of the Investment Manager’s risk monitoringprocess.
Promotion of Environmental and Social
Characteristics
The Investment Manager promotes environmental andsocial characteristics by integrating a range of
responsible investment measures into the investment
decision-making process, as well as ensuring that thecompanies in which the Portfolio invests follow good
governance practices.
Information about the environmental or social
characteristics promoted by the Portfolio and theirintegration into the investment process is available in the
SFDR RTS Annex of the Prospectus.
1 Market capitalisation refers to the total value of a company’s shares. The

free-float adjusted method of calculating market capitalisation includes only
shares available for purchase in public equity markets so excludes, forexample, shares held privately, by the company itself and its affiliates or by
governments.

20/11/2023

20/11/2023

Name change:

Name change:

Threadneedle (Lux) – European Smaller Companies

CT (Lux) European Smaller Companies

Investment objective and policy change:

Investment objective and policy change:

The European Smaller Companies Portfolio seeks toachieve capital appreciation by investing principally in theequity securities of European Smaller Companies(excluding the United Kingdom). For this Portfolio,
European Smaller Companies are companies that are
not represented in the top 225 companies in the FTSE
World Europe ex UK Index at the time of purchase.

The European Smaller Companies Portfolio seeks toachieve capital appreciation by investing principally inthe equity securities of European Smaller Companies(excluding the United Kingdom). For this Portfolio,
European Smaller Companies are companies that are
not represented in the top 225 companies in the FTSE
World Europe ex UK Index at the time of purchase.

The Portfolio may use financial derivative instruments for The Portfolio may use financial derivative instruments forhedging purposes.
hedging purposes.
The Portfolio is actively managed in reference to the
MSCI Europe ex UK Small Cap Index. The index isbroadly representative of the companies in which thePortfolio invests, and provides a suitable target
benchmark against which Portfolio performance will bemeasured and evaluated over time. The Portfolio
promotes environmental and social characteristics byaiming to compare favourably against the index overrolling 12-month periods when assessed according to the
Columbia Threadneedle ESG Materiality Rating, as set
out below. The index is not designed to specificallyconsider environmental or social characteristics. The
Sub-Advisor has discretion to select investments withweightings different to the index, and that are not in theindex, and the Portfolio may display significant
divergence from the index.
Deviations from the index, including guidance on thelevel of risk relative to the index, will be considered aspart of the Sub-Advisor’s risk monitoring process, toensure the overall level of risk is broadly consistent with

22

For the purposes of managing liquidity, the Portfolio may
hold ancillary liquid assets (i.e. bank deposits at sight),
and may also hold bank deposits, Money Market
Instruments or money market funds for treasury
purposes. In normal market conditions, investments inthese assets or instruments will not exceed 10% of thePortfolio's Net Asset Value.
The Portfolio is actively managed in reference to the
MSCI Europe ex UK Small Cap Index. The index isbroadly representative of the companies in which thePortfolio invests, and provides a suitable target
benchmark against which Portfolio performance will bemeasured and evaluated over time. The index is notdesigned to specifically consider environmental or social
characteristics.
The Sub-Advisor has discretion to select investmentswith weightings different to the index, and that are not in
the index, and the Portfolio may display significant
divergence from the index.

Details of Significant Events
Columbia Threadneedle (Lux) I; Columbia Threadneedle (Lux) II

Columbia Threadneedle (Lux) I
Portfolio Name

Date of
Significant Details before Significant Event
Event
the index. In line with its active management strategy,
there may be significant deviation from the index.
Promotion of Environmental and Social
Characteristics
The Sub-Advisor promotes environmental and social
characteristics by integrating a range of responsible
investment measures into the investment decisionmaking process.

Details after Significant Event
Deviations from the index, including guidance on thelevel of risk relative to the index, will be considered aspart of the Sub-Advisor’s risk monitoring process.
Promotion of Environmental and Social
Characteristics

The Sub-Advisor promotes environmental and social
characteristics by integrating a range of responsible
investment measures into the investment decisionmaking process, as well as ensuring that the companies
Over rolling 12-month periods, the Portfolio aims tocompare favourably with the MSCI Europe ex UK Small in which the Portfolio invests follow good governance
Cap Index according to the Columbia Threadneedle ESG practices.
Materiality Rating - a proprietary model which builds on
Information about the environmental or social
the Sustainability and Accounting Standards Board
characteristics promoted by the Portfolio and their(SASB®) framework. This model identifies material
integration into the investment process is available in theenvironmental, social and governance (“ESG”) factors
SFDR RTS Annex of the Prospectus.
across a broad range of sectors, and provides an insight
into the management focus and standards of operating
practices of a company. The Sub-Advisor considers thatcompanies that manage ESG risks effectively are better
positioned to address future challenges, and capitaliseon unknown and known future business opportunities.
Companies that lead on the most material ESG metrics
should be well positioned to build competitive advantage
and sustain their long-term future.
The Portfolio also aims to exclude companies thatbreach accepted international standards and principles(e.g. the United Nations Global Compact). Companies inbreach may be assessed as suitable for investment by
the Portfolio, if in the opinion of the Sub-Advisor there
are tangible mitigating factors for the company to be
held.
The Sub-Advisor ensures that at least:• 90% of equity securities issued by large companies
domiciled in developed countries; and• 75% of equity securities issued by large companies
domiciled in Emerging Market Countries, or by small andmedium companies,
held by the Portfolio are rated against the abovemeasures. For the purposes of this test, small companies
are those with a market capitalisation below €5 billion,
medium companies are those between €5 billion and €10billion and large companies are those above €10 billion.
To support and enhance the promotion of environmental
and social characteristics, the Sub-Advisor will seek
proactive engagement with companies with a view toinfluencing management teams to improve theirpractices, for example on issues relating to carbon
emissions.
Further information on the Portfolio investment
guidelines, including the Columbia Threadneedle ESG
Materiality Rating methodology and engagement policy isavailable at columbiathreadneedle.com.
The Portfolio is categorised as one that promotes
environmental or social characteristics under Article 8 of
the EU Regulation 2019/2088 on sustainability-related
disclosures in the financial services sector (SFDR).

23

Details of Significant Events
Columbia Threadneedle (Lux) I; Columbia Threadneedle (Lux) II

Columbia Threadneedle (Lux) I
Portfolio Name

Date of
Significant Details before Significant Event
Event
31/07/2023

01/12/2021

Details after Significant Event

Benchmark change:

Benchmark change:

EMIX Smaller European Companies Ex UK Index

MSCI Europe ex UK Small Cap Index

Investment objective and policy change:

Investment objective and policy change:

The European Smaller Companies Portfolio seeks toachieve capital appreciation by investing principally in theequity securities of European Smaller Companies(excluding the United Kingdom). For this Portfolio,
European Smaller Companies are companies that are
not represented in the top 225 companies in the FTSE
World Europe ex UK Index at the time of purchase.

The European Smaller Companies Portfolio seeks toachieve capital appreciation by investing principally inthe equity securities of European Smaller Companies(excluding the United Kingdom). For this Portfolio,
European Smaller Companies are companies that are
not represented in the top 225 companies in the FTSE
World Europe ex UK Index at the time of purchase.

The Portfolio may use financial derivative instruments for The Portfolio may use financial derivative instruments
for hedging purposes.
hedging purposes.
The Portfolio is actively managed in reference to the
EMIX Smaller European Companies Ex UK Index. The
index is broadly representative of the companies in which
the Portfolio invests, and provides a suitable target
benchmark against which Portfolio performance will bemeasured and evaluated over time. The Sub-Advisor
has discretion to select investments with weightings
different to the index, and that are not in the index, and
the Portfolio may display significant divergence from theindex.
Deviations from the index, including guidance on thelevel of risk relative to the index, will be considered aspart of the Sub-Advisor’s risk monitoring process, toensure the overall level of risk is broadly consistent with
the index. In line with its active management strategy,
there may be significant deviation from the index.

The Portfolio is actively managed in reference to the
EMIX Smaller European Companies Ex UK Index. The
index is broadly representative of the companies inwhich the Portfolio invests, and provides a suitabletarget benchmark against which Portfolio performance
will be measured and evaluated over time. The Portfolio
promotes environmental and social characteristics byaiming to compare favourably against the index overrolling 12-month periods when assessed according to
the Columbia Threadneedle ESG Materiality Rating, as
set out below. The index is not designed to specificallyconsider environmental or social characteristics. The
Sub-Advisor has discretion to select investments withweightings different to the index, and that are not in theindex, and the Portfolio may display significant
divergence from the index.
Deviations from the index, including guidance on thelevel of risk relative to the index, will be considered aspart of the Sub-Advisor’s risk monitoring process, toensure the overall level of risk is broadly consistent with
the index. In line with its active management strategy,
there may be significant deviation from the index.
Promotion of Environmental and Social
Characteristics
The Sub-Advisor promotes environmental and social
characteristics by integrating a range of responsible
investment measures into the investment decisionmaking process.

24

Over rolling 12-month periods, the Portfolio aims tocompare favourably with the EMIX Smaller European
Companies Ex UK Index according to the Columbia
Threadneedle ESG Materiality Rating - a proprietarymodel which builds on the Sustainability andAccounting Standards Board (SASB®) framework. Thismodel identifies material environmental, social andgovernance (“ESG”) factors across a broad range ofsectors, and provides an insight into the management
focus and standards of operating practices of acompany. The Sub-Advisor considers that companies
that manage ESG risks effectively are better positioned
to address future challenges, and capitalise on
unknown and known future business opportunities.
Companies that lead on the most material ESG metrics
should be well positioned to build competitive
advantage and sustain their long-term future.

Details of Significant Events
Columbia Threadneedle (Lux) I; Columbia Threadneedle (Lux) II

Columbia Threadneedle (Lux) I
Portfolio Name

Date of
Significant Details before Significant Event
Event

Details after Significant Event
The Portfolio also aims to exclude companies thatbreach accepted international standards and principles(e.g. the United Nations Global Compact). Companies
in breach may be assessed as suitable for investmentby the Portfolio, if in the opinion of the Sub-Advisor
there are tangible mitigating factors for the company to
be held.
The Sub-Advisor ensures that at least:• 90% of equity securities issued by large companies
domiciled in developed countries; and• 75% of equity securities issued by large companies
domiciled in Emerging Market Countries, or by small
and medium companies,
held by the Portfolio are rated against the abovemeasures. For the purposes of this test, small
companies are those with a market capitalisation below€5 billion, medium companies are those between €5billion and €10 billion and large companies are thoseabove €10 billion.
To support and enhance the promotion ofenvironmental and social characteristics, the SubAdvisor will seek proactive engagement with companies
with a view to influencing management teams to
improve their practices, for example on issues relating
to carbon emissions.
Further information on the Portfolio investment
guidelines, including the Columbia Threadneedle ESG
Materiality Rating methodology and engagement policy
is available at columbiathreadneedle.com.
The Portfolio is categorised as one that promotes
environmental or social characteristics under Article 8 of
the EU Regulation 2019/2088 on sustainability-related
disclosures in the financial services sector (SFDR).

20/11/2023

20/11/2023

CT (Lux) European Social Bond

Name change:

Name change:

Threadneedle (Lux) – European Social BondCT (Lux) European Social Bond

Investment objective and policy change:

Investment objective and policy change:

The European Social Bond Portfolio seeks to achieve a
total return from income and capital appreciation by
investing in debt securities that are considered to support
or fund socially beneficial activities and development
principally in Europe.

The European Social Bond Portfolio is actively
managed and seeks to achieve a total return fromincome and capital appreciation by investing in debt
securities that are considered to provide positive social
outcomes by supporting or funding socially beneficial
activities and development principally in Europe.

To meet its objective, the Portfolio invests principally inall forms of debt securities that are rated Investment
Grade and issued by a government or a supranational,
public, private or voluntary and/or charitable sector
organisation, whether they have a fixed, floating, variable
or index-linked rate or have a zero coupon. These
securities may include covered bonds, agency bonds,
mortgage and asset-backed securities (the mortgage andasset-backed securities not exceeding 10% of thePortfolio’s Net Asset Value) and Contingent Convertible
Bonds (not exceeding 10% of the Portfolio’s Net Asset
Value). The Sub-Advisor will select debt securities thatare rated as social investments under the Social Rating
Methodology, as described below.

25

To meet its objective, the Portfolio invests at least 90%
of its net assets in all forms of debt securities issued bya government or a supranational, public, private or
voluntary and/or charitable sector organisation, whether
they have a fixed, floating, variable or index-linked rateor have a zero coupon. These securities may include
covered bonds, agency bonds, mortgage and assetbacked securities (the mortgage and asset-backed
securities not exceeding 10% of the Portfolio’s Net
Asset Value) and Contingent Convertible Bonds (notexceeding 10% of the Portfolio’s Net Asset Value).
The Portfolio will not invest or have more than 10% ofDetails of Significant Events
Columbia Threadneedle (Lux) I; Columbia Threadneedle (Lux) II

Columbia Threadneedle (Lux) I
Portfolio Name

Date of
Significant Details before Significant Event
Event
Secondarily, the Portfolio may hold cash, near cash,
Money Market Instruments and other debt securities.
These encompass any wider, material businessinvolvement exposures the issuers may have, such as tothe production of alcohol, tobacco, gambling, adultentertainment or controversial weapons, or to activities
deemed to breach the UN Global Compact.
The Portfolio will not invest or have more than 10% of its
net assets in debt securities that are rated below
Investment Grade, provided that such securities are notrated below B- or equivalent by any NRSRO at the timeof purchase.

Details after Significant Event
its net assets in debt securities that are rated below
Investment Grade, provided that such securities are notrated below B- or equivalent by any NRSRO at the timeof purchase.
For the purposes of managing liquidity, the Portfolio
may hold ancillary liquid assets (i.e. bank deposits atsight) and may also hold bank deposits, Money Market
Instruments or money market funds, for treasury
purposes. In normal market conditions, investment inthese assets or instruments will not exceed 10% of thePortfolio's Net Asset Value.

The Sub-Advisor will only select debt securities that are
rated as social investments under the Social Rating
For the purposes of managing liquidity, the Portfolio may Methodology, as described below, as well as ensuringhold ancillary liquid assets (i.e. bank deposit at sight) and that the issuers of these securities follow good
may hold bank deposits, money market instruments orgovernance practices. This means that the Submoney market funds, for treasury purposes. In normal
Advisor will apply these non-financial selection criteria
market conditions, investment in ancillary liquid assets,
to at least 90% of the total net assets of the Portfolio,bank deposits, money market instruments or money
excluding investments in ancillary liquid assets, bankmarket funds will not exceed 10% of the Portfolio's net
deposits, money market instruments or money market
asset value.
funds for liquidity or treasury purposes.
The Portfolio is actively managed in reference to the ICE
BofA Euro Non-Sovereign Index (50%) and ICE BofA
Euro Corporate Euroland Issuers Index (50%). The
index is broadly representative of the securities in which
the Portfolio invests, and provides a suitable target
benchmark against which Portfolio performance will bemeasured and evaluated over time. Accordingly, theindex is not designed to specifically consider social
characteristics. The Sub-Advisor has discretion to selectinvestments with weightings different to the index, andthat are not in the index, and the Portfolio may display
significant divergence from the index.

The Portfolio is not managed in reference to abenchmark.
The ICE BofA Euro Non-Sovereign Index (50%) and
ICE BofA Euro Corporate Euroland Issuers Index (50%)
is currently used as a point of comparison against which
the Portfolio’s financial performance may be compared.
Through the application of the investment andassessment process set out below, the Sub-Advisor
expects to exclude at least 20% of the constituents of
the index. The Portfolio is otherwise not subject to any
constraints in relation to the comparator index, and as aresult of the application of the Social Rating
Methodology is expected to exhibit significant deviationfrom the index.

Deviations from the index, including guidance on thelevel of risk relative to the index, will be considered aspart of the Sub-Advisor’s risk monitoring process, toensure the overall level of risk is broadly consistent with
the index. In line with its active management strategy,
there may be significant deviation from the index.

Investment process

Overview of the investment and assessment
processes

The Sub-Advisor’s investment process to achieve thesocial objective is summarised as follows:

Investment process

1. Creating the social universe of investments byidentifying categories of bonds with higher potential fordelivering one of 7 areas of social outcome (such asaffordable housing, health and welfare, economic
regeneration and development) while excluding thosewith negative social characteristics.

The Sub-Advisor will select the debt securities based on
credit analysis and the social rating and categorisation
produced under the Social Rating Methodology. The
Social Rating Methodology is a proprietary categorisation
and rating model developed by the Sub-Advisor, whichanalyses the social characteristics of each potential
investment. Under the methodology, each investment will
be analyzed under a two-stream process that:(i) assesses the broad social intensity and intentionality
associated with the use of a bond’s proceeds, tocategorize it as either an impact investment, aninvestment with impact, as development finance or as
being general financing;(ii) applies a three stage assessment model thatexamines and scores nine aspects of the focus andsocial outcomes attributable to a bond, across fields of

26

Overview of the investment and assessment
processes

2. Adhering to particular social norms to ensure that nobond held by the Portfolio violates set standards.
3. A focus on positive inclusion by carrying out adetailed assessment of the bond’s contribution topositive social outcomes.
4. Ongoing governance, monitoring, engagement andreporting to maintain and enhance the Portfolio’s social
focus and standards.
In applying the investment process, the Sub-Advisor will
select the debt securities based on credit analysis andthe social rating and categorisation produced under theDetails of Significant Events
Columbia Threadneedle (Lux) I; Columbia Threadneedle (Lux) II

Columbia Threadneedle (Lux) I
Portfolio Name

Date of
Significant Details before Significant Event
Event

Details after Significant Eventsocial development such as affordable housing, healthand welfare, education, employment, access to services
and economic regeneration and development, to derive anumerical score that, subject to a de-minimis threshold,produces a social rating of minor, moderate, good orstrong. A bond rated as, or whose rating falls, below thede-minimis threshold is subject to review and recategorization as general financing.

Social Rating Methodology. The Social Rating
Methodology is a proprietary categorisation and rating
model developed by the Sub-Advisor, which analyses
the social characteristics of each potential investment.
Under the methodology, each investment will beanalysed under a process that:

The SAP will be chaired by one of the members
nominated by INCO.

The Sub-Advisor has partnered with INCO
(http://inco.co.com/), an organisation specialising in
impact investment, to provide assistance in assessing
and reporting on the social outcomes of the Portfolio
and providing research on trends and practices relevant
to impact investment.

(i) assesses the broad social intentionality associatedwith the use of a bond’s proceeds, to categorise it as
The categorization and ratings are then used by the Sub- either an impact investment, an investment with impact,
or as development finance, otherwise the investment is
Advisor in constructing the Portfolio.
assessed as general financing and lies outside the
The Sub-Advisor will apply these non-financial selectionsocial universe eligible for investment;
criteria to at least 90% of the total net assets of the(ii) assesses the broad social intensity by applying a
Portfolio excluding liquid assets, and will use
three stage assessment model that examines ninemeasurement methods such as responsible investment
rating and social outcome-based exclusion screening to characteristics of the social outcomes attributable to abond to derive a numerical score that, subject to a deensure that the Portfolio’s ESG profile and exposure tominimis threshold, produces a social rating of minor,social outcome themes exceeds that of the index.
moderate, good or strong.
The Portfolio is categorised as one that promotes
environmental or social characteristics under Article 8 of The categorisation and ratings are then used by the
Sub-Advisor in constructing the Portfolio. A bond rated
the EU Regulation 2019/2088 on sustainability-relatedas, or whose rating falls, below the de-minimis
disclosures in the financial services sector (SFDR).
threshold is subject to review and re-categorisation as
Assessment and research process
general financing.
The Sub-Advisor has partnered with INCO
As part of its investment process, the Sub-Advisor(http://inco.co.com/), an organisation specialising inassesses the Portfolio’s investments to ensure that,
impact investment, to provide assistance in assessing
while positively contributing to social outcomes, theand reporting on the social outcomes of the Portfolio andbonds do not significantly harm other social (including
providing research on trends and practices relevant toenvironmental) sustainability objectives.
impact investment.
The Sub-Advisor considers the principal adverseTo that end, a Social Advisory Panel (or “SAP”),
impacts (“PAIs”) of its investment decisions that may
composed of 3 members nominated by the Sub-Advisor
negatively harm sustainability factors through ensuring
and 3 members nominated by INCO, has beenminimum standards, investment research andestablished to review, advise on and monitor themonitoring and engaging with issuers in respect of theapplication and development of the Social Rating
PAI indicators detailed in the SFDR RTS Annex of the
Methodology as well as to review the actual social
Prospectus.
outcomes of investments that have been made by the
Sub-Advisor.
Assessment and research process

An annual social performance report, prepared by INCO
and approved by the SAP, will be made available toinvestors.
Promotion of Social Characteristics

To that end, a Social Advisory Panel (or “SAP”),
composed of 2 members nominated by the SubAdvisor,3 members nominated by INCO and 2
Further information on the Portfolio investment
independent appointees, has been established to
guidelines, including the Columbia Threadneedle ESG
Materiality Rating methodology and engagement policy is review, advise on and monitor the application anddevelopment of the Social Rating Methodology as wellavailable at columbiathreadneedle.com.
as to review the actual social outcomes of investments
The Portfolio is categorised as one that promotes social that have been made by the Sub-Advisor.
characteristics under Article 8 of the EU Regulation
An annual social impact report, prepared by INCO and2019/2088 on sustainability-related disclosures in theapproved by the SAP, will be made available tofinancial services sector (SFDR). Information about thesocial characteristics promoted by the Portfolio and their investors.
integration into the investment process is available in the Promotion of Social Objective
SFDR RTS Annex of the Prospectus.
The Portfolio is considered to be within the scope of
Article 9 of SFDR as it has a social (and hence
sustainable) investment objective.
The Sub-Advisor promotes social characteristics.

27

Details of Significant Events
Columbia Threadneedle (Lux) I; Columbia Threadneedle (Lux) II

Columbia Threadneedle (Lux) I
Portfolio Name

Date of
Significant Details before Significant Event
Event

Details after Significant Event
Further information on the Portfolio’s investment
guidelines is included in the Social Investment
Guidelines available at columbiathreadneedle.com.
Please also refer to the General Sustainability
Disclosures Appendix of the Prospectus for further
information.
Information about the sustainable investment objectiveof the Portfolio is available in the SFDR RTS Annex of
the Prospectus.

20/11/2023

01/03/2018

01/10/2015

01/10/2015
CT (Lux) European Strategic Bond

Name change:

Name change:

Threadneedle (Lux) – European Strategic BondCT (Lux) European Strategic Bond

Benchmark change:

Benchmark change:

BofA Merrill Lynch 3-5 Year EMU Large Cap Investment
Grade Index

ICE BofA 1-7 Year All Euro Government Index (20%),ICE BofA 1-10 Year Euro Corporate Index (40%) and
ICE BofA European Currency High Yield Constrained
Index (40%)

Name change:

Name change:

Threadneedle (Lux) – Euro Active Bonds

Threadneedle (Lux) – European Strategic Bond

Investment objective and policy change:

Investment objective and policy change:

The Euro Active Bonds Portfolio seeks to achieve total
return from income and capital appreciation by investing
principally in short to-medium term European sovereign
bonds and corporate bonds, primarily issued bycompanies domiciled in the Euro Area or with significant
operations in the Euro Area.

The European Strategic Bond Portfolio seeks to achieve
total return from income and capital appreciation by
investing principally in short to-medium term European
sovereign bonds and corporate bonds (including
Contingent Convertible Bonds for up to 5% of thePortfolio’s Net Asset Value) that are Investment Gradeor non-Investment Grade, primarily issued bycompanies domiciled in Europe or with significant
operations in Europe.

The Portfolio may also use financial derivative
instruments for investment purposes, hedging andefficient portfolio management. These derivatives may
include, but are not limited to, futures on transferable
The Portfolio may also use financial derivative
securities and interest rate swaps. The Portfolio seeks to instruments for investment purposes, hedging andminimise interest rate risk if the investment environment
efficient portfolio management. These derivatives may
warrants such action. Conversely, interest rate risk of the include, but are not limited to, foreign currency
Portfolio may be increased in the countervailing scenario. exchange contracts, futures on Transferable Securities
The Net Asset Value of the Portfolio shall be expressed in and interest rate swaps. The Portfolio seeks to actively
Euro and investment decisions will be made from a Euro manage currency exposure and interest rate risk
through the use of such derivative instruments.
perspective.
20/11/2023

01/10/2020
CT (Lux) Flexible Asian Bond
07/03/2019

CT (Lux) Global Corporate Bond

02/09/2024

Name change:

Name change:

Threadneedle (Lux) – Flexible Asian BondCT (Lux) Flexible Asian Bond

Benchmark change:

Benchmark change:

J.P. Morgan JADE Global Index (50%) and J.P. Morgan
JACI Sovereign Index (Hard CCY) (50%)

J.P. Morgan Asia Credit Index Diversified

Benchmark change:

Benchmark change:

J.P. Morgan JACI Sovereign Index (Hard CCY) (50%)
and Citigroup Asian Government Bond Investible Index(USD) (50%)

J.P. Morgan JADE Global Index (50%) and J.P. Morgan
JACI Sovereign Index (Hard CCY) (50%)

Change to minimum proportion of assets insustainable investments:

Change to minimum proportion of assets insustainable investments:

28

Details of Significant Events
Columbia Threadneedle (Lux) I; Columbia Threadneedle (Lux) II

Columbia Threadneedle (Lux) I
Portfolio Name

Date of
Significant Details before Significant Event
Event
5%

Details after Significant Event
20%
Further information is available in the SFDR RTS Annexof the Prospectus.

20/11/2023

20/11/2023

Name change:

Name change:

Threadneedle (Lux) – Global Corporate BondCT (Lux) Global Corporate Bond

Investment objective and policy change:

Investment objective and policy change:

The Global Corporate Bond Portfolio seeks to achieve a
total return from income and capital appreciation by
investing principally, either directly or indirectly throughderivatives, in a portfolio focused on Investment Gradecorporate debt fixed income and floating rate securities,
and when determined appropriate cash and Money
Market Instruments. The Portfolio may also invest up to
one third of its assets in debt securities other thanInvestment Grade corporates including, but not limited to,government and below Investment Grade securities,
which may include, without being limited to, assetbacked and/or mortgage-backed Transferable Securities(not exceeding 20% of the Portfolio’s Net Asset Value).

The Global Corporate Bond Portfolio seeks to achieve a
total return from income and capital appreciation by
investing principally, either directly or indirectly throughderivatives, in a portfolio focused on Investment Gradecorporate debt fixed income and floating rate securities,
and when determined appropriate cash and Money
Market Instruments. The Portfolio may also invest up to
one third of its assets in debt securities other thanInvestment Grade corporates including, but not limited
to, government and below Investment Grade securities,
which may include, without being limited to, assetbacked and/or mortgage-backed Transferable
Securities (not exceeding 20% of the Portfolio’s Net
Asset Value).

The Portfolio may use financial derivative instruments forinvestment purposes and hedging. These derivatives
may include, but are not limited to, foreign currency
exchange and over the counter contracts, futures andoptions on Transferable Securities, interest rate swaps
and credit default swaps.
Where securities are denominated in a currency otherthan U.S. Dollars it is intended that they will typically behedged back into U.S. Dollars.
For the purposes of managing liquidity, the Portfolio may
hold ancillary liquid assets (i.e. bank deposit at sight),
and may hold bank deposits, money market instruments
or money market funds for treasury purposes. In normal
market conditions, investments in ancillary liquid assets,bank deposits, money market instruments or money
market funds will not exceed 10% of the Portfolio's net
asset value.
The Portfolio is actively managed in reference to theBloomberg Global Aggregate Corporate Index (USD
Hedged). The index is broadly representative of the
securities in which the Portfolio invests, and provides asuitable target benchmark against which Portfolio
performance will be measured and evaluated over time.
The Sub-Advisor has discretion to select investmentswith weightings different to the index, and that are not in
the index, and the Portfolio may display significant
divergence from the index.
Deviations from the index, including guidance on thelevel of risk relative to the index, will be considered aspart of the Sub-Advisor’s risk monitoring process, toensure the overall level of risk is broadly consistent with
the index. In line with its active management strategy,
there may be significant deviation from the index.

The Portfolio may use financial derivative instruments
for investment purposes and hedging. These
derivatives may include, but are not limited to, foreign
currency exchange and over the counter contracts,
futures and options on Transferable Securities, interest
rate swaps and credit default swaps.
Where securities are denominated in a currency otherthan U.S. Dollars it is intended that they will typically behedged back into U.S. Dollars.
For the purposes of managing liquidity, the Portfolio
may hold ancillary liquid assets (i.e. bank deposits atsight), and may also hold bank deposits, Money Market
Instruments or money market funds for treasury
purposes. In normal market conditions, investments inthese assets or instruments will not exceed 10% of thePortfolio's Net Asset Value.
The Portfolio is actively managed in reference to theBloomberg Global Aggregate Corporate Index (USD
Hedged). The index is broadly representative of the
securities in which the Portfolio invests, and provides asuitable target benchmark against which Portfolio
performance will be measured and evaluated over time.
The index is not designed to specifically consider
environmental or social characteristics.
The Sub-Advisor has discretion to select investmentswith weightings different to the index, and that are not in
the index, and the Portfolio may display significant
divergence from the index.
Deviations from the index, including guidance on thelevel of risk relative to the index, will be considered aspart of the Sub-Advisor’s risk monitoring process.
Promotion of Environmental and Social
Characteristics
The Sub-Advisor promotes environmental and social

29

Details of Significant Events
Columbia Threadneedle (Lux) I; Columbia Threadneedle (Lux) II

Columbia Threadneedle (Lux) I
Portfolio Name

Date of
Significant Details before Significant Event
Event

Details after Significant Eventcharacteristics by integrating a range of responsible
investment measures into the investment decisionmaking process, as well as ensuring that the companies
in which the Portfolio invests follow good governancepractices.
Information about the environmental or social
characteristics promoted by the Portfolio and theirintegration into the investment process is available in
the SFDR RTS Annex of the Prospectus.

20/11/2023

01/08/2018

01/01/2012

Name change:

Name change:

Threadneedle (Lux) – Global Dynamic Real Return

CT (Lux) Global Dynamic Real Return

Name change:

Name change:

Threadneedle (Lux) – Global Asset Allocation

Threadneedle (Lux) – Global Dynamic Real Return

Investment objective and policy change:

Investment objective and policy change:

The Global Asset Allocation Portfolio seeks to achieve a
return from income and capital appreciation through a
globally balanced investment portfolio consisting of equity
and debt securities.

The Global Asset Allocation Portfolio seeks to achieve a
return from income and capital appreciation.

The Portfolio will invest globally primarily in the equity
and fixed income securities of both government andcorporate issuers, either directly, or indirectly through
The Global Asset Allocation Portfolio will operate as afinancial derivative instruments and/or collective
separate Portfolio and will follow the objective of the
Global Focus Portfolio for its equity portion and the Global investment schemes, as well as in forward currency
exchange contracts and, when determined appropriate
Aggregate Bond Portfolio for its bond portion (including
on a defensive basis, in cash and Money Market
the use of derivatives as disclosed for such latter
Instruments. The Portfolio may also gain indirect
Portfolio).
exposure to commodities through, but not limited to,investment in collective investment schemes, securitisednotes and/or financial derivative instruments where suchderivatives’ underlying instruments are indices. The
Portfolio will not invest in physical commodities orproperty.

CT (Lux) Global Dynamic Real
ReturnThe Portfolio may use financial derivative instruments
and forward transactions for both efficient portfolio
management and investment purposes. The use ofderivatives for investment purposes may increase therisk profile of the Portfolio.
The Portfolio retains the flexibility to vary its exposure
between asset classes where it deems necessary inorder to achieve the investment objective.
20/11/2023

20/11/2023
CT (Lux) Global Emerging Market
Equities

Name change:

Name change:

Threadneedle (Lux) – Global Emerging Market Equities

CT (Lux) Global Emerging Market Equities

Investment objective and policy change:

Investment objective and policy change:

The Global Emerging Market Equities Portfolio seeks toachieve long-term capital appreciation by investing
principally in the equity securities of Emerging Market
Countries companies. These are defined as companies
domiciled in and/or whose significant activities are in
Emerging Market Countries. The Portfolio may further
invest in other securities (including fixed income
securities, other equities and Money Market Instruments).

The Global Emerging Market Equities Portfolio seeks toachieve long-term capital appreciation by investing
principally in the equity securities of Emerging Market
Countries companies. These are defined as companies
domiciled in and/or whose significant activities are in
Emerging Market Countries. The Portfolio may further
invest in other securities (including fixed income
securities, other equities and Money Market
Instruments).

The Portfolio may invest up to 30% of its Net Asset Valuein China A-Shares through the China-Hong Kong Stock
Connect Programme.

30

The Portfolio may invest up to 30% of its Net Asset
Value in China A-Shares through the China-Hong Kong

Details of Significant Events
Columbia Threadneedle (Lux) I; Columbia Threadneedle (Lux) II

Columbia Threadneedle (Lux) I
Portfolio Name

Date of
Significant Details before Significant Event
Event

Details after Significant Event

For the purposes of managing liquidity, the Portfolio may
hold ancillary liquid assets (i.e. bank deposit at sight), andmay hold bank deposits, money market instruments ormoney market funds for treasury purposes. In normal
market conditions, investments in ancillary liquid assets,bank deposits, money market instruments or money
market funds will not exceed 10% of the Portfolio's net
asset value.

Stock Connect Programme.

The Portfolio is actively managed in reference to the
MSCI Emerging Markets Index. The index is broadly
representative of the companies in which the Portfolio
invests, and provides a suitable target benchmark against
which Portfolio performance will be measured andevaluated over time. The Sub-Advisor has discretion to
select investments with weightings different to the index,
and that are not in the index, and the Portfolio may display
significant divergence from the index.

The Portfolio is actively managed in reference to the
MSCI Emerging Markets Index. The index is broadly
representative of the companies in which the Portfolio
invests, and provides a suitable target benchmark
against which Portfolio performance will be measured
and evaluated over time. The index is not designed to
specifically consider environmental or social
characteristics.

Deviations from the index, including guidance on the levelof risk relative to the index, will be considered as part of
the Sub-Advisor’s risk monitoring process, to ensure theoverall level of risk is broadly consistent with the index. In
line with its active management strategy, there may besignificant deviation from the index.

For the purposes of managing liquidity, the Portfolio may
hold ancillary liquid assets (i.e. bank deposits at sight),
and may also hold bank deposits, Money Market
Instruments or money market funds for treasury
purposes. In normal market conditions, investments inthese assets or instruments will not exceed 10% of thePortfolio's Net Asset Value.

The Sub-Advisor has discretion to select investmentswith weightings different to the index, and that are not in
the index, and the Portfolio may display significant
divergence from the index.
Deviations from the index, including guidance on thelevel of risk relative to the index, will be considered aspart of the Sub-Advisor’s risk monitoring process.
Promotion of Environmental and Social
Characteristics
The Sub-Advisor promotes environmental and social
characteristics by integrating a range of responsible
investment measures into the investment decisionmaking process, as well as ensuring that the companies
in which the Portfolio invests follow good governancepractices.
Information about the environmental or social
characteristics promoted by the Portfolio and theirintegration into the investment process is available in the
SFDR RTS Annex of the Prospectus.

CT (Lux) Global Emerging Market
Short-Term Bonds

20/11/2023

02/09/2024

Name change:

Name change:

Threadneedle (Lux) – Global Emerging Market ShortTerm Bonds

CT (Lux) Global Emerging Market Short-Term Bonds

Change to minimum proportion of assets insustainable investments:

Change to minimum proportion of assets insustainable investments:

5%20%Further information is available in the SFDR RTS Annexof the Prospectus.

CT (Lux) Global Equity Income

20/11/2023

20/11/2023

Name change:

Name change:

Threadneedle (Lux) – Global Equity Income

CT (Lux) Global Equity Income

Investment objective and policy change:

Investment objective and policy change:

The Global Equity Income Portfolio seeks to achieve
income with prospects for capital appreciation. The
Portfolio will invest principally in global equity securities.
Income will be in the form of dividend distribution.

The Global Equity Income Portfolio seeks to achieve
income with prospects for capital appreciation. The
Portfolio will invest principally in global equity securities.
Income will be in the form of dividend distribution.

The Portfolio may use financial derivative instruments for The Portfolio may use financial derivative instruments for

31

Details of Significant Events
Columbia Threadneedle (Lux) I; Columbia Threadneedle (Lux) II

Columbia Threadneedle (Lux) I
Portfolio Name

Date of
Significant Details before Significant Event
Event

Details after Significant Event

hedging purposes.

hedging purposes.

The Portfolio is actively managed in reference to the
MSCI ACWI Index. The index is broadly representativeof the companies in which the Portfolio invests, andprovides a suitable target benchmark against which
Portfolio performance will be measured and evaluatedover time. The Portfolio promotes environmental andsocial characteristics by aiming to compare favourably
against the index over rolling 12-month periods whenassessed according to the Columbia Threadneedle ESG
Materiality Rating, as set out below. The index is notdesigned to specifically consider environmental or social
characteristics. The Sub-Advisor has discretion to selectinvestments with weightings different to the index, andthat are not in the index, and the Portfolio may display
significant divergence from the index.

For the purposes of managing liquidity, the Portfolio may
hold ancillary liquid assets (i.e. bank deposits at sight),
and may hold bank deposits, Money Market Instruments
or money market funds for treasury purposes. In normal
market conditions, investments in these assets or
instruments will not exceed 10% of the Portfolio's Net
Asset Value.

Deviations from the index, including guidance on thelevel of risk relative to the index, will be considered aspart of the Sub-Advisor’s risk monitoring process, toensure the overall level of risk is broadly consistent with
the index. In line with its active management strategy,
there may be significant deviation from the index.
Promotion of Environmental and Social
Characteristics
The Sub-Advisor promotes environmental and social
characteristics by integrating a range of responsible
investment measures into the investment decisionmaking process.
Over rolling 12-month periods, the Portfolio aims tocompare favourably with the MSCI ACWI Index
according to the Columbia Threadneedle ESG Materiality
Rating - a proprietary model which builds on the
Sustainability and Accounting Standards Board (SASB®)
framework. This model identifies material environmental,social and governance (“ESG”) factors across a broad
range of sectors, and provides an insight into the
management focus and standards of operating practicesof a company. The Sub-Advisor considers thatcompanies that manage ESG risks effectively are better
positioned to address future challenges, and capitaliseon unknown and known future business opportunities.
Companies that lead on the most material ESG metrics
should be well positioned to build competitive advantage
and sustain their long-term future.
The Portfolio also aims to exclude companies thatbreach accepted international standards and principles(e.g. the United Nations Global Compact). Companies inbreach may be assessed as suitable for investment by
the Portfolio, if in the opinion of the Sub-Advisor there
are tangible mitigating factors for the company to be
held.
The Sub-Advisor ensures that at least:• 90% of equity securities issued by large companies
domiciled in developed countries; and• 75% of equity securities issued by large companies
domiciled in Emerging Market Countries, or by small andmedium companies,

32

The Portfolio is actively managed in reference to the
MSCI ACWI Index. The index is broadly representativeof the companies in which the Portfolio invests, andprovides a suitable target benchmark against which
Portfolio performance will be measured and evaluatedover time. The index is not designed to specificallyconsider environmental or social characteristics.
The Sub-Advisor has discretion to select investmentswith weightings different to the index, and that are not in
the index, and the Portfolio may display significant
divergence from the index.
Deviations from the index, including guidance on thelevel of risk relative to the index, will be considered aspart of the Sub-Advisor’s risk monitoring process.
Promotion of Environmental and Social
Characteristics
The Sub-Advisor promotes environmental and social
characteristics by integrating a range of responsible
investment measures into the investment decisionmaking process, as well as ensuring that the companies
in which the Portfolio invests follow good governancepractices.
Information about the environmental or social
characteristics promoted by the Portfolio and theirintegration into the investment process is available in the
SFDR RTS Annex of the Prospectus.

Details of Significant Events
Columbia Threadneedle (Lux) I; Columbia Threadneedle (Lux) II

Columbia Threadneedle (Lux) I
Portfolio Name

Date of
Significant Details before Significant Event
Event

Details after Significant Eventheld by the Portfolio are rated against the abovemeasures. For the purposes of this test, small companies
are those with a market capitalisation below €5 billion,
medium companies are those between €5 billion and €10billion and large companies are those above €10 billion.
To support and enhance the promotion of environmental
and social characteristics, the Sub-Advisor will seek
proactive engagement with companies with a view toinfluencing management teams to improve theirpractices, for example on issues relating to carbon
emissions.
Further information on the Portfolio investment
guidelines, including the Columbia Threadneedle ESG
Materiality Rating methodology and engagement policy isavailable at columbiathreadneedle.com.
The Portfolio is categorised as one that promotes
environmental or social characteristics under Article 8 of
the EU Regulation 2019/2088 on sustainability-related
disclosures in the financial services sector (SFDR).
01/12/2021

Investment objective and policy change:

Investment objective and policy change:

The Global Equity Income Portfolio seeks to achieve
income with prospects for capital appreciation. The
Portfolio will invest principally in global equity securities.
Income will be in the form of dividend distribution.

The Global Equity Income Portfolio seeks to achieve
income with prospects for capital appreciation. The
Portfolio will invest principally in global equity securities.
Income will be in the form of dividend distribution.

The Portfolio may use financial derivative instruments for The Portfolio may use financial derivative instruments
for hedging purposes.
hedging purposes.
The Portfolio is actively managed in reference to the
MSCI ACWI Index. The index is broadly representativeof the companies in which the Portfolio invests, andprovides a suitable target benchmark against which
Portfolio performance will be measured and evaluatedover time. The Sub-Advisor has discretion to selectinvestments with weightings different to the index, andthat are not in the index, and the Portfolio may display
significant divergence from the index.
Deviations from the index, including guidance on thelevel of risk relative to the index, will be considered aspart of the Sub-Advisor’s risk monitoring process, toensure the overall level of risk is broadly consistent with
the index. In line with its active management strategy,
there may be significant deviation from the index.

The Portfolio is actively managed in reference to the
MSCI ACWI Index. The index is broadly representativeof the companies in which the Portfolio invests, andprovides a suitable target benchmark against which
Portfolio performance will be measured and evaluatedover time. The Portfolio promotes environmental andsocial characteristics by aiming to compare favourably
against the index over rolling 12-month periods whenassessed according to the Columbia Threadneedle
ESG Materiality Rating, as set out below. The index is
not designed to specifically consider environmental orsocial characteristics. The Sub-Advisor has discretion to
select investments with weightings different to theindex, and that are not in the index, and the Portfolio
may display significant divergence from the index.
Deviations from the index, including guidance on thelevel of risk relative to the index, will be considered aspart of the Sub-Advisor’s risk monitoring process, toensure the overall level of risk is broadly consistent with
the index. In line with its active management strategy,
there may be significant deviation from the index.
Promotion of Environmental and Social
Characteristics
The Sub-Advisor promotes environmental and social
characteristics by integrating a range of responsible
investment measures into the investment decisionmaking process.
Over rolling 12-month periods, the Portfolio aims tocompare favourably with the MSCI ACWI Index
according to the Columbia Threadneedle ESG

33

Details of Significant Events
Columbia Threadneedle (Lux) I; Columbia Threadneedle (Lux) II

Columbia Threadneedle (Lux) I
Portfolio Name

Date of
Significant Details before Significant Event
Event

Details after Significant Event
Materiality Rating - a proprietary model which builds on
the Sustainability and Accounting Standards Board(SASB®) framework. This model identifies material
environmental, social and governance (“ESG”) factors
across a broad range of sectors, and provides aninsight into the management focus and standards ofoperating practices of a company. The Sub-Advisor
considers that companies that manage ESG risks
effectively are better positioned to address futurechallenges, and capitalise on unknown and known
future business opportunities. Companies that lead on
the most material ESG metrics should be well
positioned to build competitive advantage and sustain
their long-term future.
The Portfolio also aims to exclude companies thatbreach accepted international standards and principles(e.g. the United Nations Global Compact). Companies
in breach may be assessed as suitable for investmentby the Portfolio, if in the opinion of the Sub-Advisor
there are tangible mitigating factors for the company to
be held.
The Sub-Advisor ensures that at least:• 90% of equity securities issued by large companies
domiciled in developed countries; and• 75% of equity securities issued by large companies
domiciled in Emerging Market Countries, or by small
and medium companies,
held by the Portfolio are rated against the abovemeasures. For the purposes of this test, small
companies are those with a market capitalisation below€5 billion, medium companies are those between €5billion and €10 billion and large companies are thoseabove €10 billion.
To support and enhance the promotion ofenvironmental and social characteristics, the SubAdvisor will seek proactive engagement with companies
with a view to influencing management teams to
improve their practices, for example on issues relating
to carbon emissions.
Further information on the Portfolio investment
guidelines, including the Columbia Threadneedle ESG
Materiality Rating methodology and engagement policy
is available at columbiathreadneedle.com.
The Portfolio is categorised as one that promotes
environmental or social characteristics under Article 8 of
the EU Regulation 2019/2088 on sustainability-related
disclosures in the financial services sector (SFDR).

CT (Lux) Global Extended Alpha

20/11/2023

02/09/2024
CT (Lux) Global Focus

Name change:

Name change:

Threadneedle (Lux) – Global Extended Alpha

CT (Lux) Global Extended Alpha

Change to minimum proportion of assets insustainable investments:

Change to minimum proportion of assets insustainable investments:

5%20%Further information is available in the SFDR RTS Annexof the Prospectus.

34

Details of Significant Events
Columbia Threadneedle (Lux) I; Columbia Threadneedle (Lux) II

Columbia Threadneedle (Lux) I
Portfolio Name

Date of
Significant Details before Significant Event
Event
20/11/2023

20/11/2023

Details after Significant Event

Name change:

Name change:

Threadneedle (Lux) – Global Focus

CT (Lux) Global Focus

Investment objective and policy change:

Investment objective and policy change:

The Global Focus Portfolio seeks to achieve capital
appreciation by investing principally in a concentrated
portfolio of equity securities of corporate issuers listed,
domiciled or conducting a significant part of theirbusiness in developed and Emerging Market Countries.
Secondarily, the Portfolio may invest in securities
convertible into equity securities and/or warrants.

The Global Focus Portfolio seeks to achieve capital
appreciation by investing principally in a concentrated
portfolio of equity securities of corporate issuers listed,
domiciled or conducting a significant part of theirbusiness in developed and Emerging Market Countries.
Secondarily, the Portfolio may invest in securities
convertible into equity securities and/or warrants.

The Portfolio is actively managed in reference to the
MSCI ACWI Index. The index is broadly representativeof the companies in which the Portfolio invests, andprovides a suitable target benchmark against which
Portfolio performance will be measured and evaluatedover time. The Portfolio promotes environmental andsocial characteristics by aiming to compare favourably
against the index over rolling 12-month periods whenassessed according to the Columbia Threadneedle ESG
Materiality Rating, as set out below. The index is notdesigned to specifically consider environmental or social
characteristics. The Sub-Advisor has discretion to selectinvestments with weightings different to the index, andthat are not in the index, and the Portfolio may display
significant divergence from the index.

For the purposes of managing liquidity, the Portfolio may
hold ancillary liquid assets (i.e. bank deposits at sight),
and may also hold bank deposits, Money Market
Instruments or money market funds for treasury
purposes. In normal market conditions, investments inthese assets or instruments will not exceed 10% of thePortfolio's Net Asset Value.

Deviations from the index, including guidance on thelevel of risk relative to the index, will be considered aspart of the Sub-Advisor’s risk monitoring process, toensure the overall level of risk is broadly consistent with
the index. In line with its active management strategy,
there may be significant deviation from the index.
Promotion of Environmental and Social
Characteristics
The Sub-Advisor promotes environmental and social
characteristics by integrating a range of responsible
investment measures into the investment decisionmaking process.
Over rolling 12-month periods, the Portfolio aims tocompare favourably with the MSCI ACWI Index
according to the Columbia Threadneedle ESG Materiality
Rating - a proprietary model which builds on the
Sustainability and Accounting Standards Board (SASB®)
framework. This model identifies material environmental,social and governance (“ESG”) factors across a broad
range of sectors, and provides an insight into the
management focus and standards of operating practicesof a company. The Sub-Advisor considers thatcompanies that manage ESG risks effectively are better
positioned to address future challenges, and capitaliseon unknown and known future business opportunities.
Companies that lead on the most material ESG metrics
should be well positioned to build competitive advantage
and sustain their long-term future.
The Portfolio also aims to exclude companies thatbreach accepted international standards and principles(e.g. the United Nations Global Compact). Companies inbreach may be assessed as suitable for investment by

35

The Portfolio is actively managed in reference to the
MSCI ACWI Index. The index is broadly representativeof the companies in which the Portfolio invests, andprovides a suitable target benchmark against which
Portfolio performance will be measured and evaluatedover time. The index is not designed to specificallyconsider environmental or social characteristics.
The Sub-Advisor has discretion to select investmentswith weightings different to the index, and that are not in
the index, and the Portfolio may display significant
divergence from the index.
Deviations from the index, including guidance on thelevel of risk relative to the index, will be considered aspart of the Sub-Advisor’s risk monitoring process.
Promotion of Environmental and Social
Characteristics
The Sub-Advisor promotes environmental and social
characteristics by integrating a range of responsible
investment measures into the investment decisionmaking process, as well as ensuring that the companies
in which the Portfolio invests follow good governancepractices.
Information about the environmental or social
characteristics promoted by the Portfolio and theirintegration into the investment process is available in the
SFDR RTS Annex of the Prospectus.

Details of Significant Events
Columbia Threadneedle (Lux) I; Columbia Threadneedle (Lux) II

Columbia Threadneedle (Lux) I
Portfolio Name

Date of
Significant Details before Significant Event
Event

Details after Significant Event

the Portfolio, if in the opinion of the Sub-Advisor there
are tangible mitigating factors for the company to be
held.
The Sub-Advisor ensures that at least:• 90% of equity securities issued by large companies
domiciled in developed countries; and• 75% of equity securities issued by large companies
domiciled in Emerging Market Countries, or by small andmedium companies,
held by the Portfolio are rated against the abovemeasures. For the purposes of this test, small companies
are those with a market capitalisation below €5 billion,
medium companies are those between €5 billion and €10billion and large companies are those above €10 billion.
To support and enhance the promotion of environmental
and social characteristics, the Sub-Advisor will seek
proactive engagement with companies with a view toinfluencing management teams to improve theirpractices, for example on issues relating to carbon
emissions.
Further information on the Portfolio investment
guidelines, including the Columbia Threadneedle ESG
Materiality Rating methodology and engagement policy isavailable at columbiathreadneedle.com.
The Portfolio is categorised as one that promotes
environmental or social characteristics under Article 8 of
the EU Regulation 2019/2088 on sustainability-related
disclosures in the financial services sector (SFDR).
01/12/2021

Investment objective and policy change:

Investment objective and policy change:

The Global Focus Portfolio seeks to achieve capital
appreciation by investing principally in a concentrated
portfolio of equity securities of corporate issuers listed,
domiciled or conducting a significant part of theirbusiness in developed and Emerging Market Countries.
Secondarily, the Portfolio may invest in securities
convertible into equity securities and/or warrants.

The Global Focus Portfolio seeks to achieve capital
appreciation by investing principally in a concentrated
portfolio of equity securities of corporate issuers listed,
domiciled or conducting a significant part of theirbusiness in developed and Emerging Market Countries.
Secondarily, the Portfolio may invest in securities
convertible into equity securities and/or warrants.

The Portfolio is actively managed in reference to the
MSCI ACWI Index. The index is broadly representativeof the companies in which the Portfolio invests, andprovides a suitable target benchmark against which
Portfolio performance will be measured and evaluatedover time. The Sub-Advisor has discretion to selectinvestments with weightings different to the index, andthat are not in the index, and the Portfolio may display
significant divergence from the index.

The Portfolio is actively managed in reference to the
MSCI ACWI Index. The index is broadly representativeof the companies in which the Portfolio invests, andprovides a suitable target benchmark against which
Portfolio performance will be measured and evaluatedover time. The Portfolio promotes environmental andsocial characteristics by aiming to compare favourably
against the index over rolling 12-month periods whenassessed according to the Columbia Threadneedle
ESG Materiality Rating, as set out below. The index is
not designed to specifically consider environmental orsocial characteristics. The Sub-Advisor has discretion to
select investments with weightings different to theindex, and that are not in the index, and the Portfolio
may display significant divergence from the index.

Deviations from the index, including guidance on thelevel of risk relative to the index, will be considered aspart of the Sub-Advisor’s risk monitoring process, toensure the overall level of risk is broadly consistent with
the index. In line with its active management strategy,
there may be significant deviation from the index.

36

Deviations from the index, including guidance on thelevel of risk relative to the index, will be considered aspart of the Sub-Advisor’s risk monitoring process, toensure the overall level of risk is broadly consistent with
the index. In line with its active management strategy,Details of Significant Events
Columbia Threadneedle (Lux) I; Columbia Threadneedle (Lux) II

Columbia Threadneedle (Lux) I
Portfolio Name

Date of
Significant Details before Significant Event
Event

Details after Significant Event
there may be significant deviation from the index.
Promotion of Environmental and Social
Characteristics
The Sub-Advisor promotes environmental and social
characteristics by integrating a range of responsible
investment measures into the investment decisionmaking process.
Over rolling 12-month periods, the Portfolio aims tocompare favourably with the MSCI ACWI Index
according to the Columbia Threadneedle ESG
Materiality Rating - a proprietary model which builds on
the Sustainability and Accounting Standards Board(SASB®) framework. This model identifies material
environmental, social and governance (“ESG”) factors
across a broad range of sectors, and provides aninsight into the management focus and standards ofoperating practices of a company. The Sub-Advisor
considers that companies that manage ESG risks
effectively are better positioned to address futurechallenges, and capitalise on unknown and known
future business opportunities. Companies that lead on
the most material ESG metrics should be well
positioned to build competitive advantage and sustain
their long-term future.
The Portfolio also aims to exclude companies thatbreach accepted international standards and principles(e.g. the United Nations Global Compact). Companies
in breach may be assessed as suitable for investmentby the Portfolio, if in the opinion of the Sub-Advisor
there are tangible mitigating factors for the company to
be held.
The Sub-Advisor ensures that at least:• 90% of equity securities issued by large companies
domiciled in developed countries; and• 75% of equity securities issued by large companies
domiciled in Emerging Market Countries, or by small
and medium companies,
held by the Portfolio are rated against the abovemeasures. For the purposes of this test, small
companies are those with a market capitalisation below€5 billion, medium companies are those between €5billion and €10 billion and large companies are thoseabove €10 billion.
To support and enhance the promotion ofenvironmental and social characteristics, the SubAdvisor will seek proactive engagement with companies
with a view to influencing management teams to
improve their practices, for example on issues relating
to carbon emissions.
Further information on the Portfolio investment
guidelines, including the Columbia Threadneedle ESG
Materiality Rating methodology and engagement policy
is available at columbiathreadneedle.com.
The Portfolio is categorised as one that promotes
environmental or social characteristics under Article 8 of
the EU Regulation 2019/2088 on sustainability-related37

Details of Significant Events
Columbia Threadneedle (Lux) I; Columbia Threadneedle (Lux) II

Columbia Threadneedle (Lux) I
Portfolio Name

Date of
Significant Details before Significant Event
Event

Details after Significant Event
disclosures in the financial services sector (SFDR).

29/07/2011

29/07/2011

20/11/2023

CT (Lux) Global Investment Grade
Credit Opportunities

01/09/2021

01/03/2019

20/11/2023

01/09/2021

Name change:

Name change:

Threadneedle (Lux) – World Equities

Threadneedle (Lux) – Global Focus

Investment objective and policy change:

Investment objective and policy change:

The World Equities Portfolio seeks to achieve capital
appreciation by investing principally in a globally
diversified portfolio of equity securities of corporate
issuers located in developed and emerging market
countries. Secondarily, the Portfolio may invest in
securities convertible into equity securities and/or
warrants.

The Global Focus Portfolio seeks to achieve capital
appreciation by investing principally in a concentrated
portfolio of equity securities of corporate issuers listed,
domiciled or conducting a significant part of theirbusiness in developed and emerging market countries.
Secondarily, the Portfolio may invest in securities
convertible into equity securities and/or warrants.

Name change:

Name change:

Threadneedle (Lux) – Global Investment Grade Credit
Opportunities

CT (Lux) Global Investment Grade Credit Opportunities

Benchmark change:

Benchmark change:

ICE BofA Euro Currency 1-Month Deposit Bid Rate
Constant Maturity Index (Local Total Return)

Compounded euro short-term rate (€STR) average rate,
1 month tenor

Benchmark change:

Benchmark change:

Citigroup EUR 1 Month Eurodeposit

ICE BofA Euro Currency 1-Month Deposit Bid Rate
Constant Maturity Index (Local Total Return)

Name change:

Name change:

Threadneedle (Lux) – Global Multi Asset Income

CT (Lux) Global Multi Asset Income

Benchmark change:

Benchmark change:

N/A - no benchmark.

MSCI ACWI Index (45%),
ICE BofA European Currency High Yield Excluding
Subordinated Financials Constrained Index (USD
Hedged) (30%),
Bloomberg Global Aggregate Index (USD Hedged)(20%),
30-day Average Secured Overnight Financing Rate
(SOFR) (5%)

CT (Lux) Global Multi Asset Income
01/09/2021

Investment objective and policy change:

Investment objective and policy change:

The Global Multi Asset Income Portfolio seeks toachieve an income with the prospect of capital
appreciation over the medium to long term.

The Global Multi Asset Income Portfolio seeks toachieve an income with the prospect of capital
appreciation over the medium to long term.

The Portfolio is actively managed and will invest
principally in global fixed income and global equity
securities. The Portfolio may further invest in cash andother securities globally (including Money Market
Instruments, currencies, REITs, convertible debt
securities and other asset classes). The Portfolio will
follow a flexible asset allocation policy to achieve theinvestment objective, and this may result in the Portfolio
having no exposure to particular asset classes.

The Portfolio is actively managed and will typicallymaintain a 40-60% allocation to global equity securities
and a 40-60% allocation to global fixed income
securities (including those rated below Investment
Grade). The Portfolio may further invest in cash andother securities globally (including Money Market
Instruments, currencies, REITs, convertible debt
securities and other asset classes).

The Portfolio may invest up to 10% in other UCITS or

38

The Portfolio’s exposure to fixed income securities
which are either distressed or in default will not exceedDetails of Significant Events
Columbia Threadneedle (Lux) I; Columbia Threadneedle (Lux) II

Columbia Threadneedle (Lux) I
Portfolio Name

Date of
Significant Details before Significant Event
Event
UCIs, and may use derivatives for investment purposes
and hedging, including the generation of additional
income. Such derivatives may include but are not limited
to, futures and options, interest rate swaps, and foreign
currency exchange contracts.

Details after Significant Event
10% of the Portfolio’s net assets. The Portfolio will not
actively purchase such securities.
The Portfolio may invest up to 10% in other UCITS or
UCIs, and may use derivatives for investment
purposes and hedging, including the generation of
additional income. Such derivatives may include but
are not limited to, futures and options, interest rate
swaps, and foreign currency exchange contracts.
The Portfolio is actively managed in reference to the
MSCI ACWI Index (45%), ICE BofA European
Currency High Yield Excluding SubordinatedFinancials Constrained Index (USD Hedged) (30%),
Bloomberg Global Aggregate Index (USD Hedged)(20%) and 30-day Average Secured Overnight
Financing Rate (SOFR) (5%). The index is broadly
representative of the securities in which the Portfolio
invests, and provides a suitable target benchmark
against which Portfolio performance will be measured
and evaluated over time. The Sub-Advisor has
discretion to select investments with weightings
different to the index, and that are not in the index, and
the Portfolio may display significant divergence fromthe index.
Deviations from the index, including guidance on thelevel of risk relative to the index, will be considered aspart of the Sub-Advisor’s risk monitoring process, toensure the overall level of risk is broadly consistent
with the index. In line with its active management
strategy, there may be significant deviation from theindex.

04/11/2014

04/11/2014

Name change:

Name change:

Threadneedle (Lux) – Multi Asset Target Alpha

Threadneedle (Lux) – Global Multi Asset Income

Investment objective and policy change:

Investment objective and policy change:

The Multi Asset Target Alpha Portfolio seeks to achieve
an absolute return.

The Global Multi Asset Income Portfolio seeks toachieve an income with the prospect of capital
appreciation over the medium to long term.

The Portfolio will invest globally in equity, fixed income
and currency markets, either directly, or indirectly
through collective investment schemes and/or financial
derivative instruments, and when determined
appropriate cash and Money Market Instruments. The
Portfolio will also gain indirect exposure to commodities,
property or other assets through, but not limited to,investment in collective investment schemes,
securitised notes and/or financial derivative instruments
where such derivatives underlying instruments areindices.
The Portfolio will not invest in physical commodities orproperty.
The Portfolio may invest more than 10% and up to
100% of its assets in other UCITS or UCIs.
The Sub-Advisor’s investment process involves
independently developing a current economic view
based on fundamental analysis, then establishing theforward-looking view discounted in financial asset prices
in the market. The Sub-Advisor will make asset
allocation decisions for the benefit of the Portfolio based

39

The Portfolio will invest principally in global fixed income
and global equity securities. The Portfolio may further
invest in cash and other securities globally (including
Money Market Instruments, currencies, REITs,
convertible debt securities and other asset classes). The
Portfolio will follow a flexible asset allocation policy toachieve the investment objective, and this may result in
the Portfolio having no exposure to particular asset
classes.
The Portfolio may invest up to 10% in other UCITS or
UCIs, and may use derivatives for investment purposes
and hedging, including the generation of additional
income. Such derivatives may include but are not limited
to, futures and options, interest rate swaps, and foreign
currency exchange contracts.

Details of Significant Events
Columbia Threadneedle (Lux) I; Columbia Threadneedle (Lux) II

Columbia Threadneedle (Lux) I
Portfolio Name

Date of
Significant Details before Significant Event
Event

Details after Significant Eventon disconnects identified between the current andforward-looking views. The Sub-Advisor will implement
the strategy through exposure to various asset classes
as described above (including through the use of both
long and short financial derivative instruments), thatwhen combined, display a low correlation to equity
market returns.
02/09/2024

Change to minimum proportion of assets insustainable investments:

Change to minimum proportion of assets insustainable investments:

5%20%Further information is available in the SFDR RTS Annexof the Prospectus.

20/11/2023

20/11/2023

Name change:

Name change:

Threadneedle (Lux) – Global SelectCT (Lux) Global SelectInvestment objective and policy change:

Investment objective and policy change:

The Global Select Portfolio seeks to achieve capital
appreciation by investing principally in equity securities
issued by companies globally. The “select” investment
approach means that the Portfolio has the flexibility totake significant stock and sector positions, which maylead to increased levels of volatility.

The Global Select Portfolio seeks to achieve capital
appreciation by investing principally in equity securities
issued by companies globally. The “select” investment
approach means that the Portfolio has the flexibility totake significant stock and sector positions, which maylead to increased levels of volatility.

The Portfolio may use financial derivative instruments for The Portfolio may use financial derivative instruments
hedging purposes.
for hedging purposes.

CT (Lux) Global SelectThe Portfolio is actively managed in reference to the
MSCI ACWI Index. The index is broadly representativeof the companies in which the Portfolio invests, andprovides a suitable target benchmark against which
Portfolio performance will be measured and evaluatedover time. The Portfolio promotes environmental andsocial characteristics by aiming to compare favourably
against the index over rolling 12-month periods whenassessed according to the Columbia Threadneedle ESG
Materiality Rating, as set out below. The index is notdesigned to specifically consider environmental or social
characteristics. The Sub-Advisor has discretion to selectinvestments with weightings different to the index, andthat are not in the index, and the Portfolio may display
significant divergence from the index.
Deviations from the index, including guidance on thelevel of risk relative to the index, will be considered aspart of the Sub-Advisor’s risk monitoring process, toensure the overall level of risk is broadly consistent with
the index. In line with its active management strategy,
there may be significant deviation from the index.
Promotion of Environmental and Social
Characteristics
The Sub-Advisor promotes environmental and social
characteristics by integrating a range of responsible
investment measures into the investment decisionmaking process.

For the purposes of managing liquidity, the Portfolio
may hold ancillary liquid assets (i.e. bank deposits atsight), and may also hold bank deposits, Money Market
Instruments or money market funds for treasury
purposes. In normal market conditions, investments inthese assets or instruments will not exceed 10% of thePortfolio's Net Asset Value.
The Portfolio is actively managed in reference to the
MSCI ACWI Index. The index is broadly representativeof the companies in which the Portfolio invests, andprovides a suitable target benchmark against which
Portfolio performance will be measured and evaluatedover time. The index is not designed to specificallyconsider environmental or social characteristics.
The Sub-Advisor has discretion to select investmentswith weightings different to the index, and that are not in
the index, and the Portfolio may display significant
divergence from the index.
Deviations from the index, including guidance on thelevel of risk relative to the index, will be considered aspart of the Sub-Advisor’s risk monitoring process.
Promotion of Environmental and Social
Characteristics
The Sub-Advisor promotes environmental and social
characteristics by integrating a range of responsible
investment measures into the investment decisionmaking process, as well as ensuring that the companies
in which the Portfolio invests follow good governancepractices.

Over rolling 12-month periods, the Portfolio aims tocompare favourably with the MSCI ACWI Index
according to the Columbia Threadneedle ESG Materiality
Information about the environmental or social
Rating - a proprietary model which builds on the40

Details of Significant Events
Columbia Threadneedle (Lux) I; Columbia Threadneedle (Lux) II

Columbia Threadneedle (Lux) I
Portfolio Name

Date of
Significant Details before Significant Event
Event

Details after Significant Event

Sustainability and Accounting Standards Board (SASB®) characteristics promoted by the Portfolio and theirframework. This model identifies material environmental, integration into the investment process is available insocial and governance (“ESG”) factors across a broad
the SFDR RTS Annex of the Prospectus.
range of sectors, and provides an insight into the
management focus and standards of operating practicesof a company. The Sub-Advisor considers thatcompanies that manage ESG risks effectively are better
positioned to address future challenges, and capitaliseon unknown and known future business opportunities.
Companies that lead on the most material ESG metrics
should be well positioned to build competitive advantage
and sustain their long-term future.
The Portfolio also aims to exclude companies thatbreach accepted international standards and principles(e.g. the United Nations Global Compact). Companies inbreach may be assessed as suitable for investment by
the Portfolio, if in the opinion of the Sub-Advisor there
are tangible mitigating factors for the company to be
held.
The Sub-Advisor ensures that at least:• 90% of equity securities issued by large companies
domiciled in developed countries; and• 75% of equity securities issued by large companies
domiciled in Emerging Market Countries, or by small andmedium companies,
held by the Portfolio are rated against the abovemeasures. For the purposes of this test, small companies
are those with a market capitalisation below €5 billion,
medium companies are those between €5 billion and €10billion and large companies are those above €10 billion.
To support and enhance the promotion of environmental
and social characteristics, the Sub-Advisor will seek
proactive engagement with companies with a view toinfluencing management teams to improve theirpractices, for example on issues relating to carbon
emissions.
Further information on the Portfolio investment
guidelines, including the Columbia Threadneedle ESG
Materiality Rating methodology and engagement policy isavailable at columbiathreadneedle.com.
The Portfolio is categorised as one that promotes
environmental or social characteristics under Article 8 of
the EU Regulation 2019/2088 on sustainability-related
disclosures in the financial services sector (SFDR).
01/12/2021

Investment objective and policy change:

Investment objective and policy change:

The Global Select Portfolio seeks to achieve capital
appreciation by investing principally in equity securities
issued by companies globally. The “select” investment
approach means that the Portfolio has the flexibility totake significant stock and sector positions, which maylead to increased levels of volatility.

The Global Select Portfolio seeks to achieve capital
appreciation by investing principally in equity securities
issued by companies globally. The “select” investment
approach means that the Portfolio has the flexibility totake significant stock and sector positions, which maylead to increased levels of volatility.

The Portfolio may use financial derivative instruments for The Portfolio may use financial derivative instruments
hedging purposes.
for hedging purposes.
The Portfolio is actively managed in reference to the
MSCI ACWI Index. The index is broadly representativeof the companies in which the Portfolio invests, and41

The Portfolio is actively managed in reference to the
MSCI ACWI Index. The index is broadly representativeof the companies in which the Portfolio invests, andDetails of Significant Events
Columbia Threadneedle (Lux) I; Columbia Threadneedle (Lux) II

Columbia Threadneedle (Lux) I
Portfolio Name

Date of
Significant Details before Significant Event
Event
provides a suitable target benchmark against which
Portfolio performance will be measured and evaluatedover time. The Sub-Advisor has discretion to selectinvestments with weightings different to the index, andthat are not in the index, and the Portfolio may display
significant divergence from the index.
Deviations from the index, including guidance on thelevel of risk relative to the index, will be considered aspart of the Sub-Advisor’s risk monitoring process, toensure the overall level of risk is broadly consistent with
the index. In line with its active management strategy,
there may be significant deviation from the index.

Details after Significant Event
provides a suitable target benchmark against which
Portfolio performance will be measured and evaluatedover time. The Portfolio promotes environmental andsocial characteristics by aiming to compare favourably
against the index over rolling 12-month periods whenassessed according to the Columbia Threadneedle
ESG Materiality Rating, as set out below. The index is
not designed to specifically consider environmental orsocial characteristics. The Sub-Advisor has discretion to
select investments with weightings different to theindex, and that are not in the index, and the Portfolio
may display significant divergence from the index.
Deviations from the index, including guidance on thelevel of risk relative to the index, will be considered aspart of the Sub-Advisor’s risk monitoring process, toensure the overall level of risk is broadly consistent with
the index. In line with its active management strategy,
there may be significant deviation from the index.
Promotion of Environmental and Social
Characteristics
The Sub-Advisor promotes environmental and social
characteristics by integrating a range of responsible
investment measures into the investment decisionmaking process.
Over rolling 12-month periods, the Portfolio aims tocompare favourably with the MSCI ACWI Index
according to the Columbia Threadneedle ESG
Materiality Rating - a proprietary model which builds on
the Sustainability and Accounting Standards Board(SASB®) framework. This model identifies material
environmental, social and governance (“ESG”) factors
across a broad range of sectors, and provides aninsight into the management focus and standards ofoperating practices of a company. The Sub-Advisor
considers that companies that manage ESG risks
effectively are better positioned to address futurechallenges, and capitalise on unknown and known
future business opportunities. Companies that lead on
the most material ESG metrics should be well
positioned to build competitive advantage and sustain
their long-term future.
The Portfolio also aims to exclude companies thatbreach accepted international standards and principles(e.g. the United Nations Global Compact). Companies
in breach may be assessed as suitable for investmentby the Portfolio, if in the opinion of the Sub-Advisor
there are tangible mitigating factors for the company to
be held.
The Sub-Advisor ensures that at least:• 90% of equity securities issued by large companies
domiciled in developed countries; and• 75% of equity securities issued by large companies
domiciled in Emerging Market Countries, or by small
and medium companies,
held by the Portfolio are rated against the abovemeasures. For the purposes of this test, small
companies are those with a market capitalisation below€5 billion, medium companies are those between €542Details of Significant Events
Columbia Threadneedle (Lux) I; Columbia Threadneedle (Lux) II

Columbia Threadneedle (Lux) I
Portfolio Name

Date of
Significant Details before Significant Event
Event

Details after Significant Eventbillion and €10 billion and large companies are thoseabove €10 billion.
To support and enhance the promotion ofenvironmental and social characteristics, the SubAdvisor will seek proactive engagement with companies
with a view to influencing management teams to
improve their practices, for example on issues relating
to carbon emissions.
Further information on the Portfolio investment
guidelines, including the Columbia Threadneedle ESG
Materiality Rating methodology and engagement policy
is available at columbiathreadneedle.com.
The Portfolio is categorised as one that promotes
environmental or social characteristics under Article 8 of
the EU Regulation 2019/2088 on sustainability-related
disclosures in the financial services sector (SFDR).

CT (Lux) Global Social Bond

20/11/2023

02/09/2024

Name change:

Name change:

Threadneedle (Lux) – Global Social BondCT (Lux) Global Social Bond

Change to minimum proportion of assets insustainable investments:

Change to minimum proportion of assets insustainable investments:

5%20%Further information is available in the SFDR RTS Annexof the Prospectus.

20/11/2023

20/11/2023

CT (Lux) Global Smaller Companies

Name change:

Name change:

Threadneedle (Lux) – Global Smaller Companies

CT (Lux) Global Smaller Companies

Investment objective and policy change:

Investment objective and policy change:

The Global Smaller Companies Portfolio seeks toachieve capital appreciation by investing principally in theequity securities of Global Smaller Companies. The
Portfolio may further invest in other securities (including
fixed income securities, other equities and Money Market
Instruments).

The Global Smaller Companies Portfolio seeks toachieve capital appreciation by investing principally inthe equity securities of Global Smaller Companies. The
Portfolio may further invest in other securities (including
fixed income securities, other equities and Money Market
Instruments).

The Portfolio is actively managed in reference to the
MSCI World Small Cap Index. The index is broadly
representative of the companies in which the Portfolio
invests, and provides a suitable target benchmark
against which Portfolio performance will be measured
and evaluated over time. The Portfolio promotes
environmental and social characteristics by aiming tocompare favourably against the index over rolling 12month periods when assessed according to the
Columbia Threadneedle ESG Materiality Rating, as set
out below. The index is not designed to specificallyconsider environmental or social characteristics. The
Sub-Advisor has discretion to select investments withweightings different to the index, and that are not in theindex, and the Portfolio may display significant
divergence from the index.

For the purposes of managing liquidity, the Portfolio may
hold ancillary liquid assets (i.e. bank deposits at sight),
and may also hold bank deposits, Money Market
Instruments or money market funds for treasury
purposes. In normal market conditions, investments inthese assets or instruments will not exceed 10% of thePortfolio's Net Asset Value.

Deviations from the index, including guidance on thelevel of risk relative to the index, will be considered aspart of the Sub-Advisor’s risk monitoring process, toensure the overall level of risk is broadly consistent with
the index. In line with its active management strategy,

43

The Portfolio is actively managed in reference to the
MSCI World Small Cap Index. The index is broadly
representative of the companies in which the Portfolio
invests, and provides a suitable target benchmark
against which Portfolio performance will be measured
and evaluated over time. The index is not designed to
specifically consider environmental or social
characteristics.
The Sub-Advisor has discretion to select investmentswith weightings different to the index, and that are not in
the index, and the Portfolio may display significant
divergence from the index.
Deviations from the index, including guidance on theDetails of Significant Events
Columbia Threadneedle (Lux) I; Columbia Threadneedle (Lux) II

Columbia Threadneedle (Lux) I
Portfolio Name

Date of
Significant Details before Significant Event
Eventthere may be significant deviation from the index.
Promotion of Environmental and Social
Characteristics
The Sub-Advisor promotes environmental and social
characteristics by integrating a range of responsible
investment measures into the investment decisionmaking process.
Over rolling 12-month periods, the Portfolio aims tocompare favourably with the MSCI World Small Cap
Index according to the Columbia Threadneedle ESG
Materiality Rating - a proprietary model which builds on
the Sustainability and Accounting Standards Board(SASB®) framework. This model identifies material
environmental, social and governance (“ESG”) factors
across a broad range of sectors, and provides an insight
into the management focus and standards of operating
practices of a company. The Sub-Advisor considers thatcompanies that manage ESG risks effectively are better
positioned to address future challenges, and capitaliseon unknown and known future business opportunities.
Companies that lead on the most material ESG metrics
should be well positioned to build competitive advantage
and sustain their long-term future.
The Portfolio also aims to exclude companies thatbreach accepted international standards and principles(e.g. the United Nations Global Compact). Companies inbreach may be assessed as suitable for investment by
the Portfolio, if in the opinion of the Sub-Advisor there
are tangible mitigating factors for the company to be
held.
The Sub-Advisor ensures that at least:• 90% of equity securities issued by large companies
domiciled in developed countries; and• 75% of equity securities issued by large companies
domiciled in Emerging Market Countries, or by small andmedium companies,
held by the Portfolio are rated against the abovemeasures. For the purposes of this test, small companies
are those with a market capitalisation below €5 billion,
medium companies are those between €5 billion and €10billion and large companies are those above €10 billion.
To support and enhance the promotion of environmental
and social characteristics, the Sub-Advisor will seek
proactive engagement with companies with a view toinfluencing management teams to improve theirpractices, for example on issues relating to carbon
emissions.
Further information on the Portfolio investment
guidelines, including the Columbia Threadneedle ESG
Materiality Rating methodology and engagement policy isavailable at columbiathreadneedle.com.
The Portfolio is categorised as one that promotes
environmental or social characteristics under Article 8 of
the EU Regulation 2019/2088 on sustainability-related
disclosures in the financial services sector (SFDR).

44

Details after Significant Eventlevel of risk relative to the index, will be considered aspart of the Sub-Advisor’s risk monitoring process.
Promotion of Environmental and Social
Characteristics
The Sub-Advisor promotes environmental and social
characteristics by integrating a range of responsible
investment measures into the investment decisionmaking process, as well as ensuring that the companies
in which the Portfolio invests follow good governancepractices.
Information about the environmental or social
characteristics promoted by the Portfolio and theirintegration into the investment process is available in the
SFDR RTS Annex of the Prospectus.

Details of Significant Events
Columbia Threadneedle (Lux) I; Columbia Threadneedle (Lux) II

Columbia Threadneedle (Lux) I
Portfolio Name

Date of
Significant Details before Significant Event
Event
01/12/2021

Details after Significant Event

Investment objective and policy change:

Investment objective and policy change:

The Global Smaller Companies Portfolio seeks toachieve capital appreciation by investing principally in theequity securities of Global Smaller Companies. The
Portfolio may further invest in other securities (including
fixed income securities, other equities and Money Market
Instruments).

The Global Smaller Companies Portfolio seeks toachieve capital appreciation by investing principally inthe equity securities of Global Smaller Companies. The
Portfolio may further invest in other securities (including
fixed income securities, other equities and Money
Market Instruments).

The Portfolio is actively managed in reference to the
MSCI World Small Cap Index. The index is broadly
representative of the companies in which the Portfolio
invests, and provides a suitable target benchmark
against which Portfolio performance will be measured
and evaluated over time. The Sub-Advisor has
discretion to select investments with weightings different
to the index, and that are not in the index, and thePortfolio may display significant divergence from theindex.

The Portfolio is actively managed in reference to the
MSCI World Small Cap Index. The index is broadly
representative of the companies in which the Portfolio
invests, and provides a suitable target benchmark
against which Portfolio performance will be measured
and evaluated over time. The Portfolio promotes
environmental and social characteristics by aiming tocompare favourably against the index over rolling 12month periods when assessed according to the
Columbia Threadneedle ESG Materiality Rating, as set
out below. The index is not designed to specificallyconsider environmental or social characteristics. The
Sub-Advisor has discretion to select investments withweightings different to the index, and that are not in theindex, and the Portfolio may display significant
divergence from the index.

Deviations from the index, including guidance on thelevel of risk relative to the index, will be considered aspart of the Sub-Advisor’s risk monitoring process, toensure the overall level of risk is broadly consistent with
the index. In line with its active management strategy,
there may be significant deviation from the index.

Deviations from the index, including guidance on thelevel of risk relative to the index, will be considered aspart of the Sub-Advisor’s risk monitoring process, toensure the overall level of risk is broadly consistent with
the index. In line with its active management strategy,
there may be significant deviation from the index.
Promotion of Environmental and Social
Characteristics
The Sub-Advisor promotes environmental and social
characteristics by integrating a range of responsible
investment measures into the investment decisionmaking process.
Over rolling 12-month periods, the Portfolio aims tocompare favourably with the MSCI World Small Cap
Index according to the Columbia Threadneedle ESG
Materiality Rating - a proprietary model which builds on
the Sustainability and Accounting Standards Board(SASB®) framework. This model identifies material
environmental, social and governance (“ESG”) factors
across a broad range of sectors, and provides aninsight into the management focus and standards ofoperating practices of a company. The Sub-Advisor
considers that companies that manage ESG risks
effectively are better positioned to address futurechallenges, and capitalise on unknown and known
future business opportunities. Companies that lead on
the most material ESG metrics should be well
positioned to build competitive advantage and sustain
their long-term future.
The Portfolio also aims to exclude companies thatbreach accepted international standards and principles(e.g. the United Nations Global Compact). Companies
in breach may be assessed as suitable for investmentby the Portfolio, if in the opinion of the Sub-Advisor
there are tangible mitigating factors for the company to45

Details of Significant Events
Columbia Threadneedle (Lux) I; Columbia Threadneedle (Lux) II

Columbia Threadneedle (Lux) I
Portfolio Name

Date of
Significant Details before Significant Event
Event

Details after Significant Eventbe held.
The Sub-Advisor ensures that at least:• 90% of equity securities issued by large companies
domiciled in developed countries; and• 75% of equity securities issued by large companies
domiciled in Emerging Market Countries, or by small
and medium companies,
held by the Portfolio are rated against the abovemeasures. For the purposes of this test, small
companies are those with a market capitalisation below€5 billion, medium companies are those between €5billion and €10 billion and large companies are thoseabove €10 billion.
To support and enhance the promotion ofenvironmental and social characteristics, the SubAdvisor will seek proactive engagement with companies
with a view to influencing management teams to
improve their practices, for example on issues relating
to carbon emissions.
Further information on the Portfolio investment
guidelines, including the Columbia Threadneedle ESG
Materiality Rating methodology and engagement policy
is available at columbiathreadneedle.com.
The Portfolio is categorised as one that promotes
environmental or social characteristics under Article 8 of
the EU Regulation 2019/2088 on sustainability-related
disclosures in the financial services sector (SFDR).

29/11/2013

Name change:

Name change:

Threadneedle (Lux) – European Smaller Companies
Absolute Alpha

Threadneedle (Lux) – Global Smaller Companies

46

Details of Significant Events
Columbia Threadneedle (Lux) I; Columbia Threadneedle (Lux) II

Columbia Threadneedle (Lux) I
Portfolio Name

Date of
Significant Details before Significant Event
Event
29/11/2013

Details after Significant Event

Investment objective and policy change:

Investment objective and policy change:

The European Smaller Companies Absolute Alpha
Portfolio seeks to achieve an absolute return. The
Portfolio will principally invest in equity securities,
convertible debt securities and equity related derivative
instruments of European Smaller Companies, and when
determined appropriate cash and Money Market
Instruments. Secondarily, the Portfolio may invest in
securities and derivatives related to companies
headquartered outside Europe.

The Global Smaller Companies Portfolio seeks toachieve capital appreciation by investing principally inthe equity securities of smaller companies worldwide.
The Portfolio may further invest in other securities(including fixed income securities, other equities andMoney Market Instruments).

The Portfolio will take both long and short positions.
Short positions (and possibly long positions) will betaken by the use of financial derivative instruments toinclude, but not limited to, equity swaps, total/excess
return swaps, and futures and options related toindividual equity securities, related to exchange tradedfunds and/or related to indices. Hedging may also be
achieved through the purchase of exchange tradedfunds.
The Portfolio will use financial derivative instruments
and forward transactions for both efficient portfolio
management and investment purposes. The use ofderivatives may increase or decrease the risk profile of
the Portfolio.
The Net Asset Value of the Portfolio shall be expressedin Euro and investment decisions will be made from aEuro perspective.
20/11/2023

18/10/2023

18/10/2023

CT (Lux) Global Technology

Name change:

Name change:

Threadneedle (Lux) – Global Technology

CT (Lux) Global Technology

Benchmark change:

Benchmark change:

MSCI World Information Technology Index

MSCI World Information Technology 10/40 Index

Investment objective and policy change:

Investment objective and policy change:

The Global Technology Portfolio seeks to achieve longterm capital appreciation by making global investments
principally in Transferable Securities of companies withbusiness operations in technology and technologyrelated industries. Technology-related companies arethose companies that use technology extensively to
improve their business processes and applications.

The Global Technology Portfolio seeks to achieve longterm capital appreciation by investing principally in theequity securities of companies with business operationsin technology and technology-related industries
globally. Technology-related companies are thosecompanies that use technology extensively to improvetheir business processes and applications.

The Portfolio may invest in Transferable Securities ofissuers of any size and domiciled in any country. The
Portfolio will normally invest its assets in any equity
securities, including common stock, securities convertible
or exchangeable into common stock, rights and warrants
to purchase common stock and depositary receipts
representing an ownership interest in these equity
securities. The Portfolio may invest up to 25% of its
assets in preferred stock and Investment Grade debt
securities.

The Portfolio may invest in Transferable Securities ofissuers of any size and domiciled in any country. The
Portfolio will normally invest its assets in common stock,
however it may invest in other types of equity securities,
including securities convertible or exchangeable into
common stock, rights and warrants to purchasecommon stock and depositary receipts representing anownership interest in these equity securities. The
Portfolio may invest up to 25% of its assets in preferredstock and Investment Grade debt securities.

For the purposes of managing liquidity, the Portfolio may
hold ancillary liquid assets (i.e. bank deposit at sight),
and may hold bank deposits, money market instruments
or money market funds for treasury purposes. In normal
market conditions, investments in ancillary liquid assets,

For the purposes of managing liquidity, the Portfolio
may hold ancillary liquid assets (i.e. bank deposits atsight), and may also hold bank deposits, Money Market
Instruments or money market funds for treasury
purposes. In normal market conditions, investments in

47

Details of Significant Events
Columbia Threadneedle (Lux) I; Columbia Threadneedle (Lux) II

Columbia Threadneedle (Lux) I
Portfolio Name

Date of
Significant Details before Significant Event
Eventbank deposits, money market instruments or money
market funds will not exceed 10% of the Portfolio's net
asset value.
The Portfolio is actively managed in reference to the
MSCI World Information Technology Index. The index isbroadly representative of the companies in which thePortfolio invests, and provides a suitable target
benchmark against which Portfolio performance will bemeasured and evaluated over time. The Sub-Advisor
has discretion to select investments with weightings
different to the index, and that are not in the index, and
the Portfolio may display significant divergence from theindex.
Deviations from the index, including guidance on thelevel of risk relative to the index, will be considered aspart of the Sub-Advisor’s risk monitoring process, toensure the overall level of risk is broadly consistent with
the index. In line with its active management strategy,
there may be significant deviation from the index.
02/09/2024

CT (Lux) Japan Equities
20/11/2023

CT (Lux) Pan European Absolute
Alpha

20/11/2023

CT (Lux) Pan European Equity
Dividend

20/11/2023

02/09/2024

Details after Significant Eventthese assets or instruments will not exceed 10% of thePortfolio's Net Asset Value.
The Portfolio is actively managed in reference to the
MSCI World Information Technology 10/40 Index. The
index is broadly representative of the companies inwhich the Portfolio invests, and provides a suitabletarget benchmark against which Portfolio performance
will be measured and evaluated over time. The SubAdvisor has discretion to select investments withweightings different to the index, and that are not in theindex, and the Portfolio may display significant
divergence from the index.
Deviations from the index, including guidance on thelevel of risk relative to the index, will be considered aspart of the Sub-Advisor’s risk monitoring process.

Change to minimum proportion of assets insustainable investments:

Change to minimum proportion of assets insustainable investments:

N/A - no minimum commitment to sustainable
investments.

5%

Name change:

Name change:

Threadneedle (Lux) – Japan Equities

CT (Lux) Japan Equities

Further information is available in the SFDR RTS Annexof the Prospectus.

Name change:

Name change:

Threadneedle (Lux) – Pan European Absolute Alpha

CT (Lux) Pan European Absolute Alpha

Name change:

Name change:

Threadneedle (Lux) – Pan European Equity Dividend

CT (Lux) Pan European Equity Dividend

Change to minimum proportion of assets insustainable investments:

Change to minimum proportion of assets insustainable investments:

5%20%Further information is available in the SFDR RTS Annexof the Prospectus.

20/11/2023
CT (Lux) Pan European ESG
Equities

20/11/2023

Name change:

Name change:

Threadneedle (Lux) – Pan European ESG Equities

CT (Lux) Pan European ESG Equites

Investment objective and policy change:

Investment objective and policy change:

The Pan European ESG Equities Portfolio seeks toachieve capital appreciation through investment incompanies with strong or improving environmental,social and governance (ESG) characteristics.

The Pan European ESG Equities Portfolio seeks toachieve capital appreciation through investment incompanies with strong or improving environmental,social and governance (ESG) characteristics.

The Portfolio is actively managed, and invests principallyin the equity securities of large companies domiciled inEurope or with significant European activities. The
Portfolio may further invest in the equity securities ofEuropean Smaller Companies and Money Market
Instruments.

The Portfolio invests principally in the equity securitiesof large companies domiciled in Europe or withsignificant European activities. The Portfolio may further
invest in the equity securities of European Smaller
Companies and Money Market Instruments.

48

The Portfolio may use financial derivative instruments

Details of Significant Events
Columbia Threadneedle (Lux) I; Columbia Threadneedle (Lux) II

Columbia Threadneedle (Lux) I
Portfolio Name

Date of
Significant Details before Significant Event
Event

Details after Significant Event

The Portfolio may use financial derivative instruments for for hedging purposes.
hedging purposes.
For the purposes of managing liquidity, the Portfolio
may hold ancillary liquid assets (i.e. bank deposits at
For the purposes of managing liquidity, the Portfolio maysight), and may also hold bank deposits, Money Market
hold ancillary liquid assets (i.e. bank deposit at sight),
Instruments or money market funds for treasury
and may hold bank deposits, money market instruments
purposes. In normal market conditions, investments inor money market funds for treasury purposes. In normal
these assets or instruments will not exceed 10% of themarket conditions, investments in ancillary liquid assets,
Portfolio's Net Asset Value.
bank deposits, money market instruments or money
market funds will not exceed 10% of the Portfolio's net
The Portfolio is actively managed in reference to theasset value.
MSCI Europe Index. The index is broadly
representative of the companies in which the Portfolio
The Sub-Advisor focuses on selecting companies withinvests and provides a suitable target benchmark
strong or improving ESG characteristics, as outlined inagainst which Portfolio performance will be measured
the Portfolio’s ESG Investment Guidelines. Thoseand evaluated over time. The index is not designed tocompanies will demonstrate leadership through strong
specifically consider environmental or social
environmental, social, and governance practices.
characteristics.
The Sub-Advisor will use measures that compare the
The Sub-Advisor has discretion to select investments
ESG characteristics of the Portfolio against the MSCI
with weightings different to the index, and that are not in
Europe Index. This index also provides a helpful
benchmark against which the financial performance can the index, and the Portfolio may display significant
be compared. The MSCI Europe Index has been chosen divergence from the index. Deviations from the index,
for these purposes as a good representation of large and including guidance on the level of risk relative to theindex, will be considered as part of the Sub-Advisor’s
medium-sized companies within European developed
risk monitoring process.
market countries (including the UK). Accordingly, theindex is not designed to specifically consider
Promotion of Environmental and Social
environmental or social characteristics.
Characteristics
Deviations from the index, including guidance on thelevel of risk relative to the index, will be considered aspart of the Sub-Advisor’s risk monitoring process, toensure the overall level of risk is broadly consistent with
the index. In line with its active management strategy,
there may be significant deviation from the index.

The Sub-Advisor promotes environmental and social
characteristics by investing in companies that
demonstrate strong or improving ESG characteristics.
In addition, the Sub-Advisor ensures that thecompanies in which the Portfolio invests follow good
governance practices.

In keeping with its ESG Investment Guidelines, theInformation about the environmental or social
Portfolio will not invest in some sectors and companies in characteristics promoted by the Portfolio and their
the index.
integration into the investment process is available in
The Net Asset Value of the Portfolio shall be expressed the SFDR RTS Annex of the Prospectus.
in Euro and investment decisions will be made from aEuro perspective.
ESG Investment Guidelines
The Sub-Advisor’s environmental, social and governance(“ESG”) investment criteria for the Portfolio are set out in
its ESG Investment Guidelines, which may be amended
from time-to-time. These are specific to the Portfolio andare over and above the Sub-Advisor’s own normal ethicalpractices.
The Portfolio’s ESG Investment Guidelines are available
on request.
Promotion of Environmental and Social
Characteristics
The Sub-Advisor promotes environmental and social
characteristics.
The Portfolio is categorised as one that promotes
environmental or social characteristics under Article 8 of
the EU Regulation 2019/2088 on sustainability-related
disclosures in the financial services sector (SFDR).
Information about the environmental or social
characteristics promoted by the Portfolio and their49

Details of Significant Events
Columbia Threadneedle (Lux) I; Columbia Threadneedle (Lux) II

Columbia Threadneedle (Lux) I
Portfolio Name

Date of
Significant Details before Significant Event
Event

Details after Significant Event

integration into the investment process is available in the
SFDR RTS Annex of the Prospectus.
02/10/2020

02/10/2020

Name change:

Name change:

Threadneedle (Lux) – Pan European Equities

Threadneedle (Lux) – Pan European ESG Equities

Investment objective and policy change:

Investment objective and policy change:

The Pan European Equities Portfolio seeks to achieve
capital appreciation by investing principally in the equityof large companies domiciled in Europe or withsignificant European activities. The Portfolio may further
invest in the equity securities of European Smaller
Companies and other securities (including fixed income
securities, other equities and Money Market
Instruments).

The Pan European ESG Equities Portfolio seeks toachieve capital appreciation through investment incompanies with strong or improving environmental,social and governance (ESG) characteristics.

The Net Asset Value of the Portfolio shall be expressedin Euro and investment decisions will be made from aEuro perspective.

The Portfolio is actively managed, and invests
principally in the equity securities of large companies
domiciled in Europe or with significant European
activities. The Portfolio may further invest in the equity
securities of European Smaller Companies and Money
Market Instruments.
The Portfolio may use financial derivative instruments
for hedging purposes.
The Sub-Advisor focuses on selecting companies withstrong or improving ESG characteristics, as outlined in
the Portfolio’s ESG Investment Guidelines. Thosecompanies will demonstrate leadership through strong
environmental, social, and governance practices.
The Sub-Advisor will use measures that compare theESG characteristics of the Portfolio against the MSCI
Europe Index. This index also provides a helpful
benchmark against which the financial performancecan be compared. The MSCI Europe Index has beenchosen for these purposes as a good representation oflarge and medium-sized companies within European
developed market countries (including the UK).
Accordingly, the index is not designed to specificallyconsider environmental or social characteristics.
Deviations from the index, including guidance on thelevel of risk relative to the index, will be considered aspart of the Sub-Advisor’s risk monitoring process, toensure the overall level of risk is broadly consistent
with the index. In line with its active management
strategy, there may be significant deviation from theindex.
In keeping with its ESG Investment Guidelines, thePortfolio will not invest in some sectors and companies
in the index.
The Net Asset Value of the Portfolio shall be expressedin Euro and investment decisions will be made from aEuro perspective.

02/09/2024
CT (Lux) Pan European Small Cap
Opportunities

Change to minimum proportion of assets insustainable investments:

Change to minimum proportion of assets insustainable investments:

5%

15%
Further information is available in the SFDR RTS Annexof the Prospectus.

50

Details of Significant Events
Columbia Threadneedle (Lux) I; Columbia Threadneedle (Lux) II

Columbia Threadneedle (Lux) I
Portfolio Name

Date of
Significant Details before Significant Event
Event
02/09/2024

20/11/2023

20/11/2023

Details after Significant Event‘European Smaller Companies’ definition change:‘European Smaller Companies’ definition change:

European companies either headquartered in Europe or
exercising a predominant part of their activities in
Europe, that at the time of purchase are not represented
in the top 300 companies in the FTSE World Europe
Index.

European companies either headquartered in Europe or
exercising a predominant part of their activities in
Europe, that at the time of purchase, are no larger by
free-float adjusted market capitalisation than the largest
constituent of the MSCI Europe Small Cap Index.
Market capitalisation refers to the total value of acompany’s shares. The free-float adjusted method of
calculating market capitalisation includes only sharesavailable for purchase in public equity markets so
excludes, for example, shares held privately, by thecompany itself and its affiliates or by governments.

Name change:

Name change:

Threadneedle (Lux) – Pan European Small Cap
Opportunities

CT (Lux) Pan European Small Cap Opportunities

Investment objective and policy change:

Investment objective and policy change:

The Pan European Small Cap Opportunities Portfolio
seeks to achieve capital appreciation by investing
principally in the equity securities of European Smaller
Companies. The Portfolio may further invest in othersecurities (including fixed income securities, other
equities and Money Market Instruments).

The Pan European Small Cap Opportunities Portfolio
seeks to achieve capital appreciation by investing
principally in the equity securities of European Smaller
Companies. The Portfolio may further invest in othersecurities (including fixed income securities, other
equities and Money Market Instruments).

The Net Asset Value of this Portfolio shall be expressedin Euro and investment decisions will be made from aEuro perspective.

For the purposes of managing liquidity, the Portfolio
may hold ancillary liquid assets (i.e. bank deposits atsight), and may also hold bank deposits, Money Market
Instruments or money market funds for treasury
purposes. In normal market conditions, investments inthese assets or instruments will not exceed 10% of thePortfolio's Net Asset Value.

For the purposes of managing liquidity, the Portfolio may
hold ancillary liquid assets (i.e. bank deposit at sight),
and may hold bank deposits, money market instruments
or money market funds for treasury purposes. In normal
market conditions, investments in ancillary liquid assets,bank deposits, money market instruments or money
market funds will not exceed 10% of the Portfolio's net
asset value.
The Portfolio is actively managed in reference to the
MSCI Europe Small Cap Index. The index is broadly
representative of the companies in which the Portfolio
invests, and provides a suitable target benchmark
against which Portfolio performance will be measured
and evaluated over time. The Sub-Advisor has
discretion to select investments with weightings different
to the index, and that are not in the index, and thePortfolio may display significant divergence from theindex.
Deviations from the index, including guidance on thelevel of risk relative to the index, will be considered aspart of the Sub-Advisor’s risk monitoring process, toensure the overall level of risk is broadly consistent with
the index. In line with its active management strategy,
there may be significant deviation from the index.

51

The Portfolio is actively managed in reference to the
MSCI Europe Small Cap Index. The index is broadly
representative of the companies in which the Portfolio
invests, and provides a suitable target benchmark
against which Portfolio performance will be measured
and evaluated over time. The index is not designed to
specifically consider environmental or social
characteristics.
The Sub-Advisor has discretion to select investmentswith weightings different to the index, and that are not in
the index, and the Portfolio may display significant
divergence from the index.
Deviations from the index, including guidance on thelevel of risk relative to the index, will be considered aspart of the Sub-Advisor’s risk monitoring process.
Promotion of Environmental and Social
Characteristics
The Sub-Advisor promotes environmental and social
characteristics by integrating a range of responsible
investment measures into the investment decisionmaking process, as well as ensuring that the companies
in which the Portfolio invests follow good governancepractices.
Information about the environmental or social
characteristics promoted by the Portfolio and theirintegration into the investment process is available inDetails of Significant Events
Columbia Threadneedle (Lux) I; Columbia Threadneedle (Lux) II

Columbia Threadneedle (Lux) I
Portfolio Name

Date of
Significant Details before Significant Event
Event

Details after Significant Event
the SFDR RTS Annex of the Prospectus.

31/07/2023

01/02/2013

Benchmark change:

Benchmark change:

EMIX Smaller European Companies Index

MSCI Europe Small Cap Index

Name change:

Name change:

Threadneedle (Lux) – Pan European Smaller Companies Threadneedle (Lux) – Pan European Small Cap
Opportunities
02/09/2024

Change to minimum proportion of assets insustainable investments:

Change to minimum proportion of assets insustainable investments:

5%20%Further information is available in the SFDR RTS Annexof the Prospectus.

02/09/2024

20/11/2023‘European Smaller Companies’ definition change:‘European Smaller Companies’ definition change:

European companies either headquartered in Europe or
exercising a predominant part of their activities in
Europe, that at the time of purchase are not represented
in the top 300 companies in the FTSE World Europe
Index.

European companies either headquartered in Europe or
exercising a predominant part of their activities in
Europe, that at the time of purchase, are no larger by
free-float adjusted market capitalisation than the largest
constituent of the MSCI Europe Small Cap Index.
Market capitalisation refers to the total value of acompany’s shares. The free-float adjusted method of
calculating market capitalisation includes only sharesavailable for purchase in public equity markets so
excludes, for example, shares held privately, by thecompany itself and its affiliates or by governments.

Name change:

Name change:

Threadneedle (Lux) – Pan European Smaller Companies CT (Lux) Pan European Smaller Companies
CT (Lux) Pan European Smaller
Companies

20/11/2023

Investment objective and policy change:

Investment objective and policy change:

The Pan European Smaller Companies Portfolio seeks toachieve capital appreciation by investing principally in theequity securities of European Smaller Companies. The
Sub-Advisor will typically favour investments incompanies at the higher end of the smaller companies
capitalisation scale.

The Pan European Smaller Companies Portfolio seeks
to achieve capital appreciation by investing principally inthe equity securities of European Smaller Companies.
The Sub-Advisor will typically favour investments incompanies at the higher end of the smaller companies
capitalisation scale.

The Portfolio may use financial derivative instruments for The Portfolio may use financial derivative instruments forhedging purposes.
hedging purposes.
The Portfolio is actively managed in reference to the
MSCI Europe Small Cap Index. The index is broadly
representative of the companies in which the Portfolio
invests, and provides a suitable target benchmark
against which Portfolio performance will be measured
and evaluated over time. The Portfolio promotes
environmental and social characteristics by aiming tocompare favourably against the index over rolling 12month periods when assessed according to the
Columbia Threadneedle ESG Materiality Rating, as set
out below. The index is not designed to specificallyconsider environmental or social characteristics. The
Sub-Advisor has discretion to select investments withweightings different to the index, and that are not in theindex, and the Portfolio may display significant
divergence from the index.

52

For the purposes of managing liquidity, the Portfolio may
hold ancillary liquid assets (i.e. bank deposits at sight),
and may also hold bank deposits, Money Market
Instruments or money market funds for treasury
purposes. In normal market conditions, investments inthese assets or instruments will not exceed 10% of thePortfolio's Net Asset Value.
The Portfolio is actively managed in reference to the
MSCI Europe Small Cap Index. The index is broadly
representative of the companies in which the Portfolio
invests, and provides a suitable target benchmark
against which Portfolio performance will be measured
and evaluated over time. The index is not designed to
specifically consider environmental or social
characteristics.

Details of Significant Events
Columbia Threadneedle (Lux) I; Columbia Threadneedle (Lux) II

Columbia Threadneedle (Lux) I
Portfolio Name

Date of
Significant Details before Significant Event
Event
Deviations from the index, including guidance on thelevel of risk relative to the index, will be considered aspart of the Sub-Advisor’s risk monitoring process, toensure the overall level of risk is broadly consistent with
the index. In line with its active management strategy,
there may be significant deviation from the index.
Promotion of Environmental and Social
Characteristics
The Sub-Advisor promotes environmental and social
characteristics by integrating a range of responsible
investment measures into the investment decisionmaking process.
Over rolling 12-month periods, the Portfolio aims tocompare favourably with the MSCI Europe Small Cap
Index according to the Columbia Threadneedle ESG
Materiality Rating - a proprietary model which builds on
the Sustainability and Accounting Standards Board(SASB®) framework. This model identifies material
environmental, social and governance (“ESG”) factors
across a broad range of sectors, and provides an insight
into the management focus and standards of operating
practices of a company. The Sub-Advisor considers thatcompanies that manage ESG risks effectively are better
positioned to address future challenges, and capitaliseon unknown and known future business opportunities.
Companies that lead on the most material ESG metrics
should be well positioned to build competitive advantage
and sustain their long-term future.
The Portfolio also aims to exclude companies thatbreach accepted international standards and principles(e.g. the United Nations Global Compact). Companies inbreach may be assessed as suitable for investment by
the Portfolio, if in the opinion of the Sub-Advisor there
are tangible mitigating factors for the company to be
held.
The Sub-Advisor ensures that at least:• 90% of equity securities issued by large companies
domiciled in developed countries; and• 75% of equity securities issued by large companies
domiciled in Emerging Market Countries, or by small andmedium companies,
held by the Portfolio are rated against the abovemeasures. For the purposes of this test, small companies
are those with a market capitalisation below €5 billion,
medium companies are those between €5 billion and €10billion and large companies are those above €10 billion.
To support and enhance the promotion of environmental
and social characteristics, the Sub-Advisor will seek
proactive engagement with companies with a view toinfluencing management teams to improve theirpractices, for example on issues relating to carbon
emissions.
Further information on the Portfolio investment
guidelines, including the Columbia Threadneedle ESG
Materiality Rating methodology and engagement policy isavailable at columbiathreadneedle.com.
The Portfolio is categorised as one that promotes

53

Details after Significant Event
The Sub-Advisor has discretion to select investmentswith weightings different to the index, and that are not in
the index, and the Portfolio may display significant
divergence from the index.
Deviations from the index, including guidance on thelevel of risk relative to the index, will be considered aspart of the Sub-Advisor’s risk monitoring process.
Promotion of Environmental and Social
Characteristics
The Sub-Advisor promotes environmental and social
characteristics by integrating a range of responsible
investment measures into the investment decisionmaking process, as well as ensuring that the companies
in which the Portfolio invests follow good governancepractices.
Information about the environmental or social
characteristics promoted by the Portfolio and theirintegration into the investment process is available in the
SFDR RTS Annex of the Prospectus.

Details of Significant Events
Columbia Threadneedle (Lux) I; Columbia Threadneedle (Lux) II

Columbia Threadneedle (Lux) I
Portfolio Name

Date of
Significant Details before Significant Event
Event

Details after Significant Eventenvironmental or social characteristics under Article 8 of
the EU Regulation 2019/2088 on sustainability-related
disclosures in the financial services sector (SFDR).
31/07/2023

01/12/2021

Benchmark change:

Benchmark change:

EMIX Smaller European Companies Index

MSCI Europe Small Cap Index

Investment objective and policy change:

Investment objective and policy change:

The Pan European Smaller Companies Portfolio seeks toachieve capital appreciation by investing principally in theequity securities of European Smaller Companies. The
Sub-Advisor will typically favour investments incompanies at the higher end of the smaller companies
capitalisation scale.

The Pan European Smaller Companies Portfolio seeks
to achieve capital appreciation by investing principally inthe equity securities of European Smaller Companies.
The Sub-Advisor will typically favour investments incompanies at the higher end of the smaller companies
capitalisation scale.

The Portfolio may use financial derivative instruments for The Portfolio may use financial derivative instruments
for hedging purposes.
hedging purposes.
The Portfolio is actively managed in reference to the
EMIX Smaller European Companies Index. The index isbroadly representative of the companies in which thePortfolio invests, and provides a suitable target
benchmark against which Portfolio performance will bemeasured and evaluated over time. The Sub-Advisor
has discretion to select investments with weightings
different to the index, and that are not in the index, and
the Portfolio may display significant divergence from theindex.
Deviations from the index, including guidance on thelevel of risk relative to the index, will be considered aspart of the Sub-Advisor’s risk monitoring process, toensure the overall level of risk is broadly consistent with
the index. In line with its active management strategy,
there may be significant deviation from the index

The Portfolio is actively managed in reference to the
EMIX Smaller European Companies Index. The index
is broadly representative of the companies in which thePortfolio invests, and provides a suitable target
benchmark against which Portfolio performance will bemeasured and evaluated over time. The Portfolio
promotes environmental and social characteristics byaiming to compare favourably against the index overrolling 12-month periods when assessed according to
the Columbia Threadneedle ESG Materiality Rating, as
set out below. The index is not designed to specificallyconsider environmental or social characteristics. The
Sub-Advisor has discretion to select investments withweightings different to the index, and that are not in theindex, and the Portfolio may display significant
divergence from the index.
Deviations from the index, including guidance on thelevel of risk relative to the index, will be considered aspart of the Sub-Advisor’s risk monitoring process, toensure the overall level of risk is broadly consistent with
the index. In line with its active management strategy,
there may be significant deviation from the index.
Promotion of Environmental and Social
Characteristics
The Sub-Advisor promotes environmental and social
characteristics by integrating a range of responsible
investment measures into the investment decisionmaking process.
Over rolling 12-month periods, the Portfolio aims tocompare favourably with the EMIX Smaller European
Companies Index according to the Columbia
Threadneedle ESG Materiality Rating - a proprietarymodel which builds on the Sustainability andAccounting Standards Board (SASB®) framework. Thismodel identifies material environmental, social andgovernance (“ESG”) factors across a broad range ofsectors, and provides an insight into the management
focus and standards of operating practices of acompany. The Sub-Advisor considers that companies
that manage ESG risks effectively are better positioned
to address future challenges, and capitalise on
unknown and known future business opportunities.

54

Details of Significant Events
Columbia Threadneedle (Lux) I; Columbia Threadneedle (Lux) II

Columbia Threadneedle (Lux) I
Portfolio Name

Date of
Significant Details before Significant Event
Event

Details after Significant Event
Companies that lead on the most material ESG metrics
should be well positioned to build competitive
advantage and sustain their long-term future.
The Portfolio also aims to exclude companies thatbreach accepted international standards and principles(e.g. the United Nations Global Compact). Companies
in breach may be assessed as suitable for investmentby the Portfolio, if in the opinion of the Sub-Advisor
there are tangible mitigating factors for the company to
be held.
The Sub-Advisor ensures that at least:• 90% of equity securities issued by large companies
domiciled in developed countries; and• 75% of equity securities issued by large companies
domiciled in Emerging Market Countries, or by small
and medium companies,
held by the Portfolio are rated against the abovemeasures. For the purposes of this test, small
companies are those with a market capitalisation below€5 billion, medium companies are those between €5billion and €10 billion and large companies are thoseabove €10 billion.
To support and enhance the promotion ofenvironmental and social characteristics, the SubAdvisor will seek proactive engagement with companies
with a view to influencing management teams to
improve their practices, for example on issues relating
to carbon emissions.
Further information on the Portfolio investment
guidelines, including the Columbia Threadneedle ESG
Materiality Rating methodology and engagement policy
is available at columbiathreadneedle.com.
The Portfolio is categorised as one that promotes
environmental or social characteristics under Article 8 of
the EU Regulation 2019/2088 on sustainability-related
disclosures in the financial services sector (SFDR).

02/09/2024

20/11/2023
CT (Lux) UK Equities

20/11/2023

Change to minimum proportion of assets insustainable investments:

Change to minimum proportion of assets insustainable investments:

N/A - no minimum commitment to sustainable
investments.

20%

Name change:

Name change:

Threadneedle (Lux) – UK Equities

CT (Lux) UK Equities

Investment objective and policy change:

Investment objective and policy change:

The UK Equities Portfolio seeks to achieve capital
appreciation by investing principally in the equity
securities of companies domiciled in the United Kingdom
or which have significant United Kingdom operations.
The Portfolio may further invest in other securities(including fixed income securities, other equities andMoney Market Instruments).

The UK Equities Portfolio seeks to achieve capital
appreciation by investing principally in the equity
securities of companies domiciled in the United
Kingdom or which have significant United Kingdom
operations. The Portfolio may further invest in othersecurities (including fixed income securities, other
equities and Money Market Instruments).

The Net Asset Value of the Portfolio shall be expressedin GBP and investment decisions will be made from a

For the purposes of managing liquidity, the Portfolio
may hold ancillary liquid assets (i.e. bank deposits at

55

Further information is available in the SFDR RTS Annexof the Prospectus.

Details of Significant Events
Columbia Threadneedle (Lux) I; Columbia Threadneedle (Lux) II

Columbia Threadneedle (Lux) I
Portfolio Name

Date of
Significant Details before Significant Event
Event
GBP perspective.
For the purposes of managing liquidity, the Portfolio may
hold ancillary liquid assets (i.e. bank deposit at sight),
and may hold bank deposits, money market instruments
or money market funds for treasury purposes. In normal
market conditions, investments in ancillary liquid assets,bank deposits, money market instruments or money
market funds will not exceed 10% of the Portfolio's net
asset value.
The Portfolio is actively managed in reference to the
FTSE All-Share Index. The index is broadly
representative of the companies in which the Portfolio
invests, and provides a suitable target benchmark
against which Portfolio performance will be measured
and evaluated over time. The Sub-Advisor has
discretion to select investments with weightings different
to the index, and that are not in the index, and thePortfolio may display significant divergence from theindex.
Deviations from the index, including guidance on thelevel of risk relative to the index, will be considered aspart of the Sub-Advisor’s risk monitoring process, toensure the overall level of risk is broadly consistent with
the index. In line with its active management strategy,
there may be significant deviation from the index.

Details after Significant Eventsight), and may also hold bank deposits, Money Market
Instruments or money market funds for treasury
purposes. In normal market conditions, investments inthese assets or instruments will not exceed 10% of thePortfolio's Net Asset Value.
The Portfolio is actively managed in reference to the
FTSE All-Share Index. The index is broadly
representative of the companies in which the Portfolio
invests, and provides a suitable target benchmark
against which Portfolio performance will be measured
and evaluated over time. The index is not designed to
specifically consider environmental or social
characteristics.
The Sub-Advisor has discretion to select investmentswith weightings different to the index, and that are not in
the index, and the Portfolio may display significant
divergence from the index.
Deviations from the index, including guidance on thelevel of risk relative to the index, will be considered aspart of the Sub-Advisor’s risk monitoring process.
Promotion of Environmental and Social
Characteristics
The Sub-Advisor promotes environmental and social
characteristics by integrating a range of responsible
investment measures into the investment decisionmaking process, as well as ensuring that the companies
in which the Portfolio invests follow good governancepractices.
Information about the environmental or social
characteristics promoted by the Portfolio and theirintegration into the investment process is available in
the SFDR RTS Annex of the Prospectus.

CT (Lux) UK Equity Income

20/11/2023

02/09/2024

20/11/2023
CT (Lux) US Contrarian Core
Equities

20/11/2023

Name change:

Name change:

Threadneedle (Lux) – UK Equity Income

CT (Lux) UK Equity Income

Change to minimum proportion of assets insustainable investments:

Change to minimum proportion of assets insustainable investments:

N/A - no minimum commitment to sustainable
investments.

10%

Name change:

Name change:

Threadneedle (Lux) – US Contrarian Core Equities

CT (Lux) US Contrarian Core Equities

Investment objective and policy change:

Investment objective and policy change:

The US Contrarian Core Equities Portfolio seeks toachieve long-term capital appreciation by investing
principally in the equity securities of large cap companies(generally over US$ 2 billion in market capitalisation, as
at time of purchase) listed, domiciled, or conducting asignificant part of their business in the United States. The
Sub-Advisor will take a contrarian approach and will
specifically target stocks that it believes are undervaluedby the market.

The US Contrarian Core Equities Portfolio seeks toachieve long-term capital appreciation by investing
principally in the equity securities of large cap
companies (generally over US$ 2 billion in market
capitalisation, as at time of purchase) listed, domiciled,or conducting a significant part of their business in the
United States. The Sub-Advisor will take a contrarian
approach and will specifically target stocks that it
believes are undervalued by the market.
The
Portfolio may use financial derivative instruments for

The Portfolio may use financial derivative instruments for

56

Further information is available in the SFDR RTS Annexof the Prospectus.

Details of Significant Events
Columbia Threadneedle (Lux) I; Columbia Threadneedle (Lux) II

Columbia Threadneedle (Lux) I
Portfolio Name

Date of
Significant Details before Significant Event
Event

Details after Significant Eventinvestment purposes, hedging and efficient portfolio
management. These derivatives may include but are notlimited to equity swaps, options, futures and foreign
currency exchange contracts.

investment purposes, hedging and efficient portfolio
management. These derivatives may include but are
not limited to equity swaps, options, futures and foreign
currency exchange contracts.

For the purposes of managing liquidity, the Portfolio may
hold ancillary liquid assets (i.e. bank deposit at sight),
and may hold bank deposits, money market instruments
or money market funds for treasury purposes. In normal
market conditions, investments in ancillary liquid assets,bank deposits, money market instruments or money
market funds will not exceed 10% of the Portfolio's net
asset value.

For the purposes of managing liquidity, the Portfolio
may hold ancillary liquid assets (i.e. bank deposits atsight), and may also hold bank deposits, Money Market
Instruments or money market funds for treasury
purposes. In normal market conditions, investments inthese assets or instruments will not exceed 10% of thePortfolio’s Net Asset Value.

The Portfolio is actively managed in reference to the S&P
500 Index. The index is broadly representative of thecompanies in which the Portfolio invests, and provides asuitable target benchmark against which Portfolio
performance will be measured and evaluated over time.
The Sub-Advisor has discretion to select investmentswith weightings different to the index, and that are not in
the index, and the Portfolio may display significant
divergence from the index.
Deviations from the index, including guidance on thelevel of risk relative to the index, will be considered aspart of the Sub-Advisor’s risk monitoring process, toensure the overall level of risk is broadly consistent with
the index. In line with its active management strategy,
there may be significant deviation from the index.

The Portfolio is actively managed in reference to the
S&P 500 Index. The index is broadly representative of
the companies in which the Portfolio invests, andprovides a suitable target benchmark against which
Portfolio performance will be measured and evaluatedover time. The index is not designed to specificallyconsider environmental or social characteristics.
The Sub-Advisor has discretion to select investmentswith weightings different to the index, and that are not in
the index, and the Portfolio may display significant
divergence from the index.
Deviations from the index, including guidance on thelevel of risk relative to the index, will be considered aspart of the Sub-Advisor’s risk monitoring process.
Promotion of Environmental and Social
Characteristics
The Sub-Advisor promotes environmental and social
characteristics by integrating a range of responsible
investment measures into the investment decisionmaking process, as well as ensuring that the companies
in which the Portfolio invests follow good governancepractices.
Information about the environmental or social
characteristics promoted by the Portfolio and theirintegration into the investment process is available in
the SFDR RTS Annex of the Prospectus.

CT (Lux) US Disciplined Core
Equities

20/11/2023

20/11/2023

CT (Lux) US High Yield Bond

03/05/2016

01/07/2015

Name change:

Name change:

Threadneedle (Lux) – US Disciplined Core Equities

CT (Lux) US Disciplined Core Equities

Name change:

Name change:

Threadneedle (Lux) – US High Yield BondCT (Lux) US High Yield Bond

Name change:

Name change:

Threadneedle (Lux) – US$ High Income Bonds

Threadneedle (Lux) – US High Yield Bond

Benchmark change:

Benchmark change:

BofA Merrill Lynch BB-B US Cash Pay High Yield Index

BofA Merrill Lynch US Cash Pay High Yield
Constrained Index

57

Details of Significant Events
Columbia Threadneedle (Lux) I; Columbia Threadneedle (Lux) II

Columbia Threadneedle (Lux) II
Portfolio Name

Date of
Significant Details before Significant Event
Event
20/11/2023

20/11/2023

CT (Lux) Sustainable Outcomes
Global Equity

Details after Significant Event

Name change:

Name change:

Columbia Threadneedle (Lux) – Sustainable Outcomes
Global Equity

CT (Lux) Sustainable Outcomes Global Equity

Investment objective and policy change:

Investment objective and policy change:

Objective

Objective

to generate capital growth through investment incompanies that are positively exposed to sustainableoutcome themes through their products and services anddisplay strong or improving environmental, social andgovernance (ESG) practices.

to generate capital growth by investing in companies
globally that are delivering positive sustainableoutcomes for the environment and/or society throughtheir products and services, and display strong
environmental, social and governance (ESG) practices.

Investment Policy

Investment Policy

The fund is actively managed and invests a minimum of
90% of its total net assets in the equity securities ofcompanies globally, including through depositary
receipts. Such investment may include the equity
securities of companies in emerging market countries
which may represent a core part of the fund’sinvestments.

The fund is actively managed and invests at least 90%
of its total net assets in the equity securities ofcompanies located anywhere in the world, including
through depositary receipts, subject to the fund’s
sustainable outcomes criteria. This includes companies
located in emerging market countries which may
represent a core part of the fund’s investments.

For the purposes of managing liquidity, the fund may
hold ancillary liquid assets (i.e. bank deposits at sight)
and may hold bank deposits, money market instruments
or money market funds for treasury purposes. In normal
market conditions, investment in these assets andinstruments will not exceed 10% of the fund’s net asset
value.
The investment manager focusses on selecting
companies delivering sustainable outcomes orprogressing towards the delivery of sustainableoutcomes, as outlined in the fund’s Sustainable
Outcomes Investment Guidelines. Those companies willoffer products and services aligned to the fund’s
sustainable outcome themes and demonstrate strong or
improving ESG practices.
The fund is actively managed in reference to the MSCIACWI Index. The fund looks to outperform the index
over rolling 5 year periods, after deduction of charges.
The index is broadly representative of the companies inwhich the fund invests and provides a suitable target
index against which fund performance will be measured
and evaluated over time. Accordingly, the index is notdesigned to specifically consider environmental or social
characteristics. The investment manager has discretion
to select investments with weightings different to theindex, and that are not in the index, and the fund may
display significant divergence from the index.
Guidelines on the level of risk relative to the index will beconsidered as part of the investment manager’s risk
monitoring process, to ensure the overall level of risk is
broadly consistent with the index. In keeping with its
Sustainable Outcomes Investment Guidelines, the fundmay not invest in some sectors and companies in theindex.
Sustainable Outcomes Investment Guidelines:
The investment manager has developed its own

58

For the purposes of managing liquidity, the fund may
hold ancillary liquid assets (i.e. bank deposits at sight),
and may also hold bank deposits, money market
instruments or money market funds for treasury
purposes. In normal market conditions, investment inthese assets or instruments will not exceed 10% of thefund’s net asset value.
The fund is actively managed in reference to the MSCIACWI Index. The fund looks to outperform the index
over rolling 5-year periods, after deduction of charges.
The index is broadly representative of the companies inwhich the fund invests and provides a suitable target
index against which fund performance will be measured
and evaluated over time. The index is used for the
purposes above and is not intended to be aligned withor used to attain the sustainable investment objective of
the fund.
The investment manager has discretion to selectinvestments with weightings different to the index, andthat are not in the index, and as a result of its
sustainable investment objective, the fund will display
significant divergence from the index.
Deviations from the index, including guidance on thelevel of risk relative to the index, will be considered aspart of the investment manager’s risk monitoringprocess.
Sustainable Outcomes Investment Guidelines:
The investment manager has developed its own
Sustainable Outcomes Investment Guidelines for thefund, which may be amended from time to time. The
two main components of these Guidelines are theapplication of a sustainable outcomes framework andthe application of sustainable outcomes-based
exclusions. The investment manager considers theprincipal adverse impacts (“PAIs”) of its investment
decisions that may negatively harm sustainability
factors through exclusions, investment research andDetails of Significant Events
Columbia Threadneedle (Lux) I; Columbia Threadneedle (Lux) II

Columbia Threadneedle (Lux) II
Portfolio Name

Date of
Significant Details before Significant Event
Event

Details after Significant Event

Sustainable Outcomes Investment criteria for the fund as
set out in its Sustainable Outcomes Investment
Guidelines, which may be amended from time to time.
These are specific to the fund and are over and above
the investment manager’s normal responsible investment
practices.

monitoring and engagement of companies. The
Sustainable Investment Guidelines and consideration of
PAIs are described in the SFDR RTS Annex of theProspectus.

• evidence strong or improving ESG practices within theirsectors which means that the investment manager may
invest in companies that at the time of investment do notdemonstrate strong ESG practices, but are in theprocess of transitioning to such practices.

The fund is considered to be within the scope of Article
9 of SFDR as it has sustainable investment as its
objective.

Columbia Threadneedle Investments is a signatory to
the Net Zero Asset Managers Initiative (“NZAMI”) and
The fund’s Sustainable Outcomes Investment Guidelines has committed to an ambition, in partnership withclients, to reach net zero emissions by 2050 or sooner
are available on request and on the Columbia
for a range of assets, including the fund. Accordingly,
Threadneedle Investments website.
the investment manager will use proactive engagement
There are two main components to the Sustainablewith companies to assist with progressing this ambition.
Outcomes Investment Guidelines as outlined below:
If after an appropriate period of engagement, a highemitting company held in the fund does not show
1) Within the universe of approved investments, theprogress in meeting minimum standards consideredframework against which the investment manager will
necessary for continued investment, then the fund willassess its investments may include the extent to which
disinvest from the company.
companies:
Derivatives and techniques• currently have the potential and are seeking to develop
The fund may use derivatives for hedging (reducing
products and services that contribute towards a betterrisks), but not for investment purposes.
future (such as in education, clean technology,
healthcare, safety and security);
SFDR Information

2) The investment manager will apply sustainableoutcome-based exclusion screening to the fund’sinvestments, which aims to exclude companies that are
unable to satisfy the fund’s Sustainable Outcomes
Investment Guidelines from time to time. By way of
example, it may seek to exclude companies where asubstantial element of the business revenue is derived
from products or services such as alcohol, tobacco,gambling, adult entertainment, the manufacture ofmilitary weapons, civilian firearms and nuclear power.
The investment manager will apply these non-financial
selection criteria to at least 90% of the total net assets ofthe fund, excluding ancillary liquid assets, bank deposits,money market funds or money market instruments forliquidity or treasury purposes, and will use measurement
methods such as responsible investment rating andsustainable outcome-based exclusion screening toensure that the fund’s ESG profile and exposure tosustainable outcome themes exceeds that of the index.
In addition to these measurements, the investment
manager will publish an annual impact report.
The investment manager will monitor its investments
against the fund’s Sustainable Outcomes Investment
Guidelines and may engage in dialogue with suchcompanies if it believes that the standards and practices
applied by these companies can be improved. In
evaluating the investment universe, the investment
manager may refer to additional sources, such asexternal rating providers that score companies on their
ESG performance, as well as the investment manager’s
own analysis and expertise in this area.
The fund is categorised as one that promotes

59

Further information on the fund’s investment guidelines
is included in the Sustainable Outcomes Investment
Guidelines available at columbiathreadneedle.com. The
investment manager publishes a sustainable outcome
report each year which is also available atwww.columbiathreadneedle.com.
Please also refer to the General Sustainability
Disclosures Appendix of the Prospectus for further
information.
Information about the sustainable investment objectiveof the Portfolio is available in the SFDR RTS Annex of
the Prospectus.

Details of Significant Events
Columbia Threadneedle (Lux) I; Columbia Threadneedle (Lux) II

Columbia Threadneedle (Lux) II
Portfolio Name

Date of
Significant Details before Significant Event
Event

Details after Significant Eventenvironmental or social characteristics under EU
Regulation 2019/2088 on sustainability-related
disclosures in the financial services sector (SFDR), anddoes not have a “sustainable investment” objective as
defined by SFDR.
Derivatives and techniques
The fund may use derivatives for hedging (reducing
risks), but not for investment purposes.

Important Information:
In the EEA and Switzerland: Issued by Threadneedle Management Luxembourg S.A. Registered with the Registre de Commerce et des Sociétés(Luxembourg), Registered No. B 110242 44, rue de la Vallée, L-2661 Luxembourg, Grand Duchy of Luxembourg.
In the UK: Threadneedle Management Luxembourg S.A. Registered with the Registre de Commerce et des Societes (Luxembourg), Registered No. B
110242, 44, rue de la Vallée, L-2661 Luxembourg, Grand Duchy of Luxembourg. Issued by Threadneedle Asset Management Limited, registered inEngland and Wales, No. 573204. Registered Office: Cannon Place, 78 Cannon Street, London EC4N 6AG. Authorised and regulated in the UK by the
Financial Conduct Authority.
In the Middle East: this document is distributed by Columbia Threadneedle Investments (ME) Limited, which is regulated by the Dubai Financial
Services Authority (DFSA). For Distributors: This document is intended to provide distributors’ with information about Group products and services andis not for further distribution. For Institutional Clients: The information in this document is not intended as financial advice and is only intended for
persons with appropriate investment knowledge and who meet the regulatory criteria to be classified as a Professional Client or Market Counterparty
and no other Person should act upon it.

60