PGIM LIMITED 2023 FCA
TCFD DISCLOSURES
ENTITY LEVEL  JUNE 2024

CONTENTS
Introduction

2Compliance Statement

2Part 1: Governance3Part 2: Strategy

4Part 3: Risk Management

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Part 4: Metrics and Targets

9

PGIM Fixed Income  PGIM Limited 2023 FCA TCFD Disclosures—Entity Level

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INTRODUCTION
This report (the “Report”) sets out PGIM Limited’s (the “Firm” or “PGIM Limited”) entity level climate related
disclosure required under the Financial Conduct Authority rules on the disclosure of climate related information (the “FCA
Rules”) and consistent with the Recommendations of the Task Force on Climate-related Financial Disclosures. This Report
is for the reporting period 1 January 2023 to 31 December 2023 (the “Reporting Period”).
This report sets out the TCFD-aligned entity-level disclosures of the Firm (the “Report”), in relation to climate-related
matters, for the reporting period 1 January 2023 to 31 December 2023 (the “Reporting Period”). Quantitative metrics inthe Report are calculated as of the last business day of the Reporting Period unless otherwise noted.
This Report relates to the relevant assets that the Firm manages and the portfolio management services provided to its
clients. The Firm’s investment management services provided to clients over their accounts and portfolios are referred to inthis report as “Portfolios”.
The Firm has prepared this Report by applying the TCFD Recommendations and Recommended Disclosures to its
portfolio management services and activities in respect of the Portfolios. This Report does not generally apply the TCFD
Recommendations and Recommended Disclosures in respect of the Firm and its broader corporate group as a commercial
enterprise.
This Report is the Firm’s first TCFD report under the FCA Rules and has been prepared on a best-efforts basis. However,climate reporting in the asset management industry is still in its infancy, and there are significant data challenges andmethodological challenges associated with climate reporting. We have included TCFD-aligned disclosures where it is fair,
clear and not misleading for us to do so. We have also explained limitations on our ability to disclose, and the steps being
taken to address those limitations.
In preparing the Report, the Firm has not directly relied on any third parties. However, where noted, certain quantitative
metrics are based on data sourced from third party sources. Further, as described in Part 1 (Governance), the Firm is part ofa larger organisation and made use of shared resources of that organisation in preparing the Report.

COMPLIANCE STATEMENT
The disclosures in this Report comply with the climate-related disclosure requirements in Chapter 2 of the FCA’s ESG
Sourcebook.

SARAH MCMULLEN, CFA
Director
Head of EMEAPGIM Fixed Income

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PART 1: GOVERNANCE
This Part of the Report discloses the Firm’s governance around climate-related risks and opportunities.

(a) The Board’s oversight of climate-related risks and opportunities
PGIM Limited is a UK based private limited company and is authorised and regulated by the UK’s Financial Conduct
Authority. The Firm is managed by its Board of Directors, comprised of executive and non-executive directors (the“Board”). PGIM Limited is part of “PGIM” which is the global asset management business of Prudential Financial, Inc. 1,(“PFI”), a publicly-listed company (NYSE Ticker: PRU) headquartered in the State of New Jersey, U.S.A. PGIM is
headquartered in Newark, New Jersey, U.S.A. and operates in the United States through PGIM, Inc., a registeredinvestment adviser with the United States’ Securities and Exchange Commission. PGIM provides investment management
and advisory services to institutional investors across public and private markets through its various global affiliates andbusinesses. PGIM Limited forms part of PGIM’s UK and EU operations.
PGIM Limited has two primary business divisions: (i) PGIM Fixed Income; and (ii) PGIM Investments.
PGIM Fixed Income operates as a globally integrated investment business through various regulated entities worldwide(“PGIM Fixed Income”) and its principal business is the provision of fixed income portfolio investment management
services for professional and institutional clients. PGIM Investments’ primary service is the offering to intermediaries of
the affiliated PGIM investment management capabilities and the distribution of PGIM funds. This Report relates to theinvestment management services provided by PGIM Limited’s fixed income business in the UK (“PGIM Fixed IncomeUK”). References to the Firm’s processes and approach generally refer to those of PGIM Fixed Income-UK, except where
specified otherwise.
The Board is ultimately responsible for governance and oversight of the activities of PGIM Limited and has written Termsof Reference which specify the matters for which the Board is directly responsible. In accordance with the Board’s Termsof Reference, the Board has delegated certain management functions to its Risk, Nomination and Remuneration
Committees. The Board has delegated the review and monitoring of climate-related risks and opportunities to the Risk
Committee and it also has a designated board member who is responsible for the oversight of PGIM Fixed Income-UK’sclimate-related matters. The Risk Committee is required to report and update the Board at least annually on ESG matters
impacting the Firm including on climate-related issues.

(b) Management’s role in assessing and managing climate-related risks and opportunities
As a global business, PGIM operates in different jurisdictions, including PGIM Limited in the UK. As part of PGIM’sgroup infrastructure, PGIM Fixed Income’s operations in PGIM Limited benefits from and also participates in the wider
support functions available from within PGIM. In that respect, PGIM Limited has representatives on PGIM Fixed Income’s
ESG policy committee (the “ESG Policy Committee”), which steers and guides PGIM Fixed Income’s overall ESG
strategy and also acts as the top global governance and decision-making body for PGIM Fixed Income on ESG and climate
related topics. Members of the ESG Policy Committee include the President and CEO of PGIM Fixed Income, as well as
its Co-Heads of ESG Research, Head of Credit, Co-CIOs, Chief Business Officer, Head of Client Advisory Group, Head of
Product Strategy, Co-Heads of Credit Research, Head of EMEA, and Head of EM Debt & FX, and the President and CEO
of PGIM Japan. Certain of these ESG Policy Committee members are also directors for PGIM Limited. The ESG Policy
Committee is supported by an ESG ratings sub-committee (the “ESG Ratings Sub-Committee”, together with the ESG
Policy Committee, the “ESG Committee”) and other ESG working groups. The ESG Ratings Sub-Committee makes
decisions on matters related to ESG integration in credit analysis, ESG impact ratings and other frameworks and tools
related to ESG assessments used in PGIM Fixed Income’s investment process whereas the other ESG working groups
consider ESG issues from their respective perspectives related to their specific functions. The remit of the ESG Policy
Committee and its supporting committees and working groups is not limited to climate-related responsibilities, and it has
no specific mandate to assess and manage climate-related risks and opportunities. However, this is the main structure at
PGIM Fixed Income where such topics may be assigned and discussed.

1

Prudential Financial, Inc. of the United States is not affiliated in any manner with Prudential plc, incorporated in the United Kingdom, or with Prudential
Assurance Company, a subsidiary of M&G plc, incorporated in the United Kingdom.

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PART 2: STRATEGYThis Part of the Report discloses the actual and potential impacts of climate-related risks and opportunities on the
Firm’s businesses, strategy, and financial planning in respect of the Portfolios where such information is material.

(a) Climate-related risks and opportunities of the Firm’s investment strategies
This sub-section of the Report sets out the Firm’s assessment of the climate-related risks and opportunities to which thePortfolios are exposed, over the short, medium and long-term.
PGIM Fixed Income is an active manager specialising in fundamental, bottom-up research. PGIM Fixed Income’s credit
analysts and economists have responsibility for assessing the risk profiles of the issuers in their coverage. PGIM Fixed
Income’s approach to managing climate-related risks and opportunities in the Portfolios leverages these core competencies.
Definition of time horizons:
For these purposes, the Firm defines the relevant time horizons for climate-related risks and opportunities in line with thetime horizons applicable when assessing investment risks and opportunities in general. These are approximately as follows:•

short term: 0-2 years•

medium term: 3-5 years•

long term: 5+ years

These time horizons take into consideration the typical investment forecasting horizons of the Portfolios’ assets. Althoughclimate-related issues often manifest themselves over the medium and longer terms, experience has shown that it isdifficult or impossible to make accurate, decision-useful predictions about the evolution of most investments’ risk profiles
over longer time horizons due the innumerable intervening events that may render such predictions incorrect, as well as theactions the Firm, issuers and other investors may take to adapt to new circumstances. Financial forecasts therefore lose
predictive power with each additional year the time horizon extends. This is not to say the Firm does not consider longerterm structural trends, only that longer-term forecasts may have less utility in making investment decisions or assessing theresilience of its strategy.
Climate risks and opportunities and their potential financial impacts:
The Firm believes that climate risks and opportunities can impact investment performance, and therefore aims to integrate thesefactors into the credit analysis processes used across all of our credit strategies. However, in keeping with its core competency ofactive, fundamental research, the Firm believes that it can best assess climate-related risks and opportunities at the issuer level
rather than at the portfolio level, especially given the weaknesses it perceives in “top down” climate risk models.
The Firm also evaluates issuers’ credit profiles from a holistic perspective, rather than separating them into thematiccomponents – climate or otherwise – as we believe all aspects of an issuer’s credit profile must be taken into account in
totality when making an investment decision. We believe that viewing thematic risks in isolation can present a view that isvery different from the overall risk assessment, as some risks can cancel each other out and others can compound on one
another. Therefore, we do not evaluate issuers’ climate risks and opportunities in isolation, but instead integrate them
directly into our fundamental credit ratings, and thus into our relative value assessments. In addition, there is often not aclear demarcation of what could be a ‘climate risk/opportunity’ versus a ‘traditional risk/opportunity.’ In many cases, theseheavily overlap, so any boundary around what is a ‘climate risk/opportunity’ instead of any other type of risk/opportunity
can be arbitrary. For example, an automaker’s EV strategy would be evaluated as part of the broader business assessment,
rather than as a standalone climate assessment.
Given the above and the need to have one overarching assessment of an issuer’s risk profile as well as the fact that wecannot always identify a clear boundary around which factors should be considered climate risks/opportunities, we do not
systematically tag the Portfolios’ aggregate exposure to specific climate risks and opportunities.
Processes used to determine materiality of impact:
It is the responsibility of PGIM Fixed Income’s credit analysts and economists (“analysts”) to assess the risk profiles of
the issuers in their coverage and to assign each issuer a proprietary fundamental credit rating. In doing so, it is their
responsibility to include any climate-related risks or opportunities that they feel are likely to be financially material,aligned with the time frame that they are considering for their fundamental credit rating. Analysts rely mainly on theirknowledge of the industries and regions in which they specialise to conduct these assessments. Where relevant, they may
also review more specific information related to climate factors, which may be provided by the issuer, obtained from thirdparty ESG research providers or alternative data sources (e.g., NGO analyses, governmental and inter-governmental
studies, etc.). Analysts may further supplement this information through engagement with the issuer. They are also
PGIM Fixed Income  PGIM Limited 2023 FCA TCFD Disclosures—Entity Level4sometimes assisted by PGIM Fixed Income’s dedicated team of ESG research specialists. Analysts are required to discuss
the most material ESG-related financial risks and opportunities they have assessed (including those related to climate, if
applicable) in the credit write ups documenting the internal credit rating for issuers in their coverage universe 2, however
they are not required to systematically “tag” specific climate risks.
Analysts are also required to assign ESG Impact Ratings to issuers in their coverage universe 3. These ratings are‘normative’ in that they focus on the most material impacts of issuers on the environment and society, agnostic of suchimpacts’ financial materiality. As a result, they are largely out of scope for this report, which is focused on financiallymaterial risks and opportunities. However, the ESG Committee has approved frameworks for assigning these ESG Impact
Ratings that includes guidance on the impacts that tend to be the most material for each industry. In considering suchimpacts and assigning ESG Impact Ratings, analysts can also sometimes gain useful insights into relatedrisks/opportunities, including those around climate change where this is a material impact. More information on PGIM
Fixed Income’s ESG Impact Ratings can be found on its website here.

(b) Impact of climate-related risks and opportunities on the Firm’s investment strategies
This sub-section of the Report sets out a summary of the impact of climate-related risks and opportunities on the Firm’s
investment strategies in respect of the Portfolios.
Climate risks and opportunities are factored into the Firm’s investment management processes for the Portfolios through the
integration of climate risks into the credit analysis process for the Portfolios as described under Section 2(b). As this is part ofthe standard credit process, it is applicable to all credit Portfolios. As a result of climate risks being integrated into the Firm’s
overall credit analysis process, and as noted above, the time horizons for assessing climate-related investment risks andopportunities are aligned with the time horizons for credit assessments more generally. At their discretion, certain analysts
may sometimes run scenarios in their financial models that incorporate one or more of the analyst’s most material climaterelated considerations, but this is not a systematic requirement.
To the extent climate-related risks and/or opportunities for an issuer do appear likely to be financially material to the relevant
analyst, this will be balanced against the issuer’s other risks and opportunities, and any mitigating factors as part of a holistic
risk assessment of the issuer. Although a climate-related risk or opportunity may appear material in isolation, it may not be as
significant when incorporated into an assessment of an issuer’s overall risk profile, and therefore may not be consideredfinancially material for that particular issuer. Or an issuer may be materially exposed to climate risks (opportunities), but still
have a favourable (unfavourable) overall risk profile due to other factors.
While the Firm aims to capture relevant climate-related risks and opportunities in its issuer-level assessments, the Firm does
not believe that currently available top-down assessments of how its Portfolios might be affected by a transition to a lowcarbon economy are especially useful for investment decision making. As a result, the Firm does not currently assess how its
Portfolios might be affected by a transition to a low-carbon economy through top down assessments, save where there is an
explicit agreement with a client to manage the relevant Portfolio(s) using top down models. In such a case, the Firm may
disclose how the relevant Portfolio might be affected by a transition to a low-carbon economy in the product-specificdisclosures for that Portfolio.
It is also important to note that managing risk effectively is not the same as avoiding all risk. The Firm’s objective is tounderstand the risks it faces and choose positions which, in the Firm’s view, have the most favourable risk-return profiles. In
that regard, analysts’ fundamental credit ratings are considered by the Firm’s portfolio managers in their relative value
assessments, which take into account investments’ risks and opportunities, as well as their pricing. Issuers with material
climate risks/opportunities can still present good/bad relative value if investors are/are not well compensated for theserisks/opportunities. Therefore, from a purely financial perspective, the presence of material climate risks would notnecessarily preclude investment in an issuer (and material climate opportunities may not be sufficient to make an investment
more attractive).
That said, the Firm manages certain Portfolios that expressly incorporate climate-related terms in their guidelines as directedby those Portfolios’ clients. These are primarily normative objectives, rather than financial objectives, and so are not designed
specifically to manage climate risks and opportunities. For instance, accounts may exclude issuers involved in activities suchas coal or oil sands, regardless of those issuers’ relative values. The Firm may also have Portfolios with guidelines targeting
reductions 4 in carbon footprint (or similar), even if this restricts them from purchasing issuers with attractive relative value.
The Firm has developed dedicated ESG Impact Ratings and a standalone Temperature Alignment Tool for clients that wish the2Credit write ups are only required for issuers where we have a meaningful exposure across the PGIM Fixed Income.

3

The coverage universe for ESG Impact Ratings includes nearly all issuers where we hold a position, except for those where our position size across thefirm is de minimis and certain tax-exempt munis, provided these are not held in accounts that utilize the ESG Impact Ratings. Certain new issuers may
also not have an ESG Impact Rating assigned in our systems on a transitory basis due to timing constraints.

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Including relative reductions against a benchmark or index.

PGIM Fixed Income  PGIM Limited 2023 FCA TCFD Disclosures—Entity Level5

pursue normative objectives such as these. However, given that PGIM Fixed Income does not generally use these tools to manage
risks, they are considered out of scope for this report. More information can be found on PGIM Fixed Income’s ESG website.
As described in Part 3 (Risk Management), it is not straightforward to define what is a “climate risk (or opportunity)” versus a“standard business risk (or opportunity)” for a given position. Any decision around where to set this boundary will ultimately beat least somewhat subjective. Further, as explained above, we believe it is critical to assess investment risks and opportunities
holistically in our investment process, rather than managing individual components of risk and opportunity in isolation.
Therefore, we believe it would be complex and potentially misleading to attempt to systematically attribute impact of climate
risks and opportunities on financial performance and financial position. As a result, we do not perform this attribution.
Nonetheless, we recognise the need to assess the risks stemming from climate change and appreciate that some clients wish to go
further in aligning their portfolios with decarbonisation objectives that go beyond strictly financial considerations. We have,therefore, developed processes and tools to address these client demands. However, again, it is not straightforward to determine
how much of our business is based specifically on these factors, and therefore we have not calculated such an attribution.

(c) Resilience of the Firm’s strategy, taking into consideration different climate-related scenarios, including a 2°C
or lower scenario
This sub-section of the Report summarises the resilience of the investment strategies for the Portfolios to climate-relatedrisks and opportunities, taking into account different climate-related scenarios.
The Firm does not currently conduct climate scenario analysis as a regular part of its investment or risk management
process. This is because the Firm believes that climate-related risks and opportunities are best assessed at the issuer level
rather than at the portfolio level. The Firm sees weaknesses in existing top-down climate models, which do not always
reflect the credit analysts’ more granular bottom-up views regarding issuers’ exposures to climate risks and do not provide
portfolio managers with decision useful information. Nonetheless, the Firm considers climate change and associated policy
and regulatory responses to be important risk factors that should be incorporated into its credit assessment and fundamental
credit ratings, especially where the issuer’s exposure to climate risk is deemed high. As part of this, analysts consider
climate scenarios where they believe risks could be material. Where scenarios are considered, these vary by sector, region,and sometimes issuer to reflect the most likely channel(s) through which climate risks may arise.
The Firm does have access to third-party data which provides the Firm with Climate Value at Risk metrics and which allows theFirm to provide the information to its clients on demand. However, given the Firm’s view that this metric often does not
sufficiently reflect credit analysts’ bottom-up fundamental assessment, the Firm does not offer it as part of its standard reporting.
It should also be noted that in assessing climate risks and opportunities as part of its credit analysis, the Firm puts moreemphasis on the most plausible scenarios. Unfortunately, current policies and pledges globally are generally not consideredby experts to be aligned with 2C or below scenarios. Most expert estimates expect warming closer to 2.5-3C based on
current or anticipated policies. Therefore, we feel it is important to consider less ambitious transition scenarios as well, andtreat these as our base case assumptions.
The Firm keeps these decisions under periodic review. If, in the future, the Firm starts to systematically use scenario
analysis, then this will be reflected in future TCFD reports.
Transition plans:
The Firm is incorporated in the UK and operates in the UK. The Firm notes that the UK Government committed in June2019 to a 100% reduction of greenhouse gas emissions by 2050 compared with 1990 levels. This is referred to as the net
zero target. The Government stated that net zero means “any emissions would be balanced by schemes to offset an
equivalent amount of greenhouse gases from the atmosphere, such as planting trees or using technology like carbon
capture and storage”.
For further details on the UK government’s net zero target, please refer to: https://commonslibrary.parliament.uk/researchbriefings/cdp-2023-0124/
The Firm has not integrated an explicit commitment to the net zero target in its management of any portfolios. This isbecause expert analysis from the UN, IPCC, IEA, Climate Action Tracker, and various other academics, institutions andNGOs all conclude that 1.5C and 2C outcomes are currently very unlikely. Limiting warming to 1.5-2C would requireemissions to be reduced by around 5.6% to 8.7% per year, every year, for the rest of this decade. In contrast, emissions
continue to rise, and the above experts project that only modest reductions would be achieved under current policies andofficial pledges. If correct, this would mean aligning a portfolio with 1.5-2C scenarios could result in lower returns and/or
greater risk for investors. Therefore, the Firm would require the explicit agreement of its clients to integrate the UK
Government’s net zero target into the management of Portfolios, and at the date of this Report, there is no instruction in
respect of the net zero target for relevant Portfolios.

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PART 3: RISK MANAGEMENT
This Part of the Report discloses how the Firm identifies, assesses, and manages climate-related risks.

(a) The Firm’s processes for identifying and assessing climate-related risksThis sub-section of the Report summarises the Firm’s processes for identifying and assessing climate-related risks. (Forreference, the material climate-related risks that have been identified in practice by the Firm are summarised in sub-section
2(a) of this Report).
The Firm has implemented processes to identify and assess sustainability / ESG risks, which includes climate-related risks
as a key category of sustainability risks in practice.
However, the Firm has not implemented any bespoke processes specifically related to climate risks alone.
Identification of sustainability risks
The Firm’s process to identify sustainability risks is from a bottom-up fundamental research perspective. Credit analysts
and economists are primarily responsible for identifying any climate-related risks that they believe are likely to be material
for the issuers in their coverage universe. These analysts are considered experts on their industries and their issuers, and so
we believe they are typically best placed to make such an evaluation. However, they are sometimes be supported byadditional research or guidance from PGIM Fixed Income’s ESG research team.
Assessment of sustainability risks
As part of the credit research process, PGIM Fixed Income analysts review information related to ESG factors, which may
be provided by the issuer, obtained from third-party ESG research providers or alternative data sources (e.g., NGOanalyses, governmental and inter-governmental studies, etc.). PGIM Fixed Income analysts may supplement thisinformation through engagement with the issuer. To the extent an ESG factor is considered by the analyst to have amaterial or a potentially material adverse impact on the financial value of the issuer, our analysts will incorporate suchrisks into their fundamental credit ratings. Fundamental credit ratings are in turn a key factor in our relative value
assessments, and our portfolio managers will consider material ESG risks and opportunities when assessing the overall
relative attractiveness of potential investments. Although our views are often informed by quantitative metrics, our ultimate
decision on how ESG issues should influence our investment decisions is largely qualitative, as with other types of risks
and opportunities.
With respect to climate change, analysts consider climate change and associated investment risk to be an important factor thatshould be incorporated in our credit assessment, especially where they deem the issuer’s exposure to climate risk to be high.
We seek to identify, understand and manage the impact of likely climate-related risks on our investments. This is achievedby a combination of approaches as applicable to different asset classes, including:•

Incorporating climate risk assessment in fundamental analysis. Where they believe these risks to be material, ouranalysts may evaluate an issuer’s exposure to climate related risks by considering their exposure to climate
regulations, consumer demands, technological risks/opportunities, and/or whether their key assets are located in areas
exposed to increased physical climate risks. They also may consider the issuer’s management and plans to reduce
their climate risk exposures going forward. This is in keeping with our general focus on fundamental, bottom up
analysis, which we feel is core to our ability to add value.

•

Focusing on sectors with high direct exposures to the physical and transition risks of climate change, including thoseparticularly exposed to supplying or consuming fossil fuels (e.g., energy, mining, utilities, transportation), industrials(e.g., producing or using products like steel, cement and aluminium), as well as the agricultural sector, our research
involves (where relevant):-

Monitoring regulatory developments and analysing potential impact on issuers-

Incorporating the risk of an increase in carbon prices or lower demand for fossil fuels-

Identifying issuers with a credible strategy for transitioning towards lower-carbon business models-

Exploring indirect climate risk vulnerabilities (e.g., physical and transition risks in supply chains)

In line with our bottom up, fundamental credit approach, we view issuers’ credit profiles from a holistic perspective, rather
than separating them into distinct components that must then be reconciled. Therefore, we do not evaluate issuers’ ESG
risks in isolation, but instead integrate them directly into our fundamental credit ratings, and thus into our relative value
assessments. In addition, there is often not a clear demarcation of what could be a ‘ESG risk’ versus a ‘traditional risk’.
PGIM Fixed Income  PGIM Limited 2023 FCA TCFD Disclosures—Entity Level

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ESG issues that relate directly to the business model, could be considered financially-material and may be considered‘business risks’, which is why such issues cannot be evaluated separately from fundamental credit analysis.

(b) Describe the Firm’s processes for managing climate-related risksThis sub-section of the Report summarises the Firm’s processes for managing climate-related risks. (For reference,
the material climate-related risks that have been identified in practice by the Firm are summarised in sub-section
2(a) of this Report).
While the Firm’s investment professionals are provided with information on credit material climate risks and areencouraged to take these risks into account when making an investment decision, credit-material climate risk would not byitself prevent the Firm from making any investment. In many cases, an issuer may have higher “climate risk” but lower
overall risk (e.g. an issuer that is more exposed to climate risk but is highly rated and lower levered may have less overallrisk than one with a weak balance sheet but less direct climate exposure). Our objective is to manage overall risk, notindividual categories of risk. Further, as a fixed income investor, our mandate is not to avoid all risk, but rather to takecalculated risks that are attractive from a relative value perspective. Thus, as stated, we do not apply any absolute risk
limits or risk appetite thresholds which relate exclusively to climate risk as a separate category of risk. Instead, creditmaterial climate risk forms part of the overall research process, and is one of many risks which may, depending on thespecific investment opportunity, be relevant to a determination of risk. Effectively, we manage climate-related risks byincorporating them into our overall fundamental credit ratings, which then allows us to integrate them into our standard
relative value and risk management processes, which we feel are the best way to holistically manage risk.

(c) How processes for identifying, assessing, and managing climate-related risks are integrated into the Firm’s
overall risk management
This sub-section of the Report summarises how the Firm’s processes for identifying, assessing and managing
climate-related risks (as summarised in sub-sections 3(a) and 3(b) of this Report, above) are integrated into theFirm’s overall risk management processes.
As an FCA-regulated investment manager, the Firm is subject to the FCA Rules in respect of investment risk management
processes. Consistent with these requirements, the Firm has:•Established and implemented risk management policies and procedures. These identify the risks which relate to
the Firm’s activities, processes and systems, and set the level of risk tolerated by the Firm;•

Adopted arrangements, processes and mechanisms to manage the risks to which the Firm is exposed, in light ofthat risk tolerance;•

Implemented monitoring processes, in respect of risk exposure and risk tolerance; and•Established a permanent Risk Management function, which is responsible for the implementation of the policies
and procedures noted above, and for reporting to senior management on risk matters.

The Firm’s sustainability risk management processes (which include climate risks), as summarised in sub-sections 3(a) and3(b) above, are integrated into the general investment processes summarised above.

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PART 4: METRICS AND TARGETS
This Part of the Report discloses the metrics and targets used to assess and manage relevant climate-related risks
and opportunities where such information is material.

(a) Metrics used by the Firm to assess climate-related risks and opportunities in line with its strategy and risk
management process
The Firm uses a variety of metrics to assess climate-related risks and opportunities across investments. As noted inprevious sections, though, our primary measure of risk is our fundamental credit ratings, which incorporate climate-relatedrisks where analysts believe these to be material. Other, more specific metrics may vary depending on the asset class,industry and/or business model. These specific metrics are not included in this entity-level report, but in some cases may be
included in individual product-level reports that are made available to the Firm’s clients on request.
Remuneration policies:
The Firm does not incorporate climate metrics into the Firm’s remuneration policies for its personnel.
Internal carbon pricing:
The Firm does not use internal carbon prices at the entity level.
Alignment with a “well below 2 degrees” scenario:
At present, investment teams are not systematically measuring the extent to which Portfolios are aligned with a “wellbelow 2 degrees” scenario; however, the Firm has developed a tool in order to understand the extent to which investment
grade and high yield issuers are credibly aligned with different temperature scenarios, the results of which may be sharedin the product-level reports.

(b) Greenhouse gas (GHG) emissions data
In this sub-section of the Report, we disclose certain climate-related data. The specific data points in this section arerecommended by the TCFD and required under the FCA Rules. However, the Firm believes that aggregated emissions dataat the portfolio-level is not usually an effective measure of a portfolio’s climate-related risks and opportunities. As noted
elsewhere in the Report, we feel that such risks and opportunities are best assessed at the issuer-level, which allows to themto take into account the unique circumstances of each issuer.
This data is provided on an aggregated basis, across all of the Portfolios managed by the Firm. The data points below relate
to the emissions of the investments held by the Portfolios (and not, for the avoidance of doubt, to the Firm itself). Note that
the TCFD metrics are designed specifically for corporate issuers, however the Portfolios also hold positions in asset classes
such as sovereigns, municipals, structured products, and other non-corporate asset classes. We have included TCFD
metrics for corporate issuers, and some commonly used metrics for sovereign issuers. However, we have not included
metrics for other asset classes representing the remainder of the Portfolios as we feel there are not robust methodologies forcalculating emissions in these asset classes. In many cases, there is no commonly-used methodology at all, and in others,
only very rough proxies that we feel are not informative and potentially misleading due to their high degree of imprecision.

CORPORATE ISSUERSNOTE: All metrics in the section below only apply to corporate issuers. Values are scaled to the size of the corporate
sleeve of the Portfolios, which comprises 68.2% of the total AUM in the Portfolios.

Scope 1
Scope 2
Scope 3
Scope 1 & 2
Scope 1 & 2 with PGIM Fixed Income Estimates*
Scope 1-3

Weighted Average
Carbon Intensity(tCO2e / USD 1M sales)
255
39
1,180
292
289
1,474

%
Reported
71.8%
69.3%
0.0%
70.5%
70.5%
0.0%

%
Estimated
20.8%
23.3%
92.4%
22.5%
26.3%
92.4%

%
Missing
7.4%
7.4%
7.6%
6.9%
3.2%
7.6%

Scope 1
Scope 2
Scope 3
Scope 1 & 2
Scope 1 & 2 with PGIM Fixed Income Estimates*
Scope 1-3

Carbon Footprint(tCO2e per USD 1M Invested)
72
12
440
84
85
522

%
Reported
62.0%
60.2%
0.0%
60.7%
60.7%
0.0%

%
Estimated
12.5%
14.4%
74.3%
14.0%
28.4%
74.3%

%
Missing
25.5%
25.5%
25.7%
25.3%
10.9%
25.7%

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9

Scope 1
Scope 2
Scope 3
Scope 1 & 2
Scope 1 & 2 with PGIM Fixed Income Estimates*
Scope 1-3

Absolute GHG Emissions(tCO2e attributed)*
661,880
109,046
4,052,774
774,915
936,867
4,802,309%
Reported
62.0%
60.2%
0.0%
60.7%
60.7%
0.0%

%
Estimated
12.5%
14.4%
74.3%
14.0%
28.4%
74.3%

%
Missing
25.5%
25.5%
25.7%
25.3%
10.9%
25.7%

Scope 1
Scope 2
Scope 3
Scope 1 & 2
Scope 1-3

Carbon Intensity(tCO2e attributed / USD 1M
sales attributed)
178
29
1,157
207
1,359

%
Reported
62.2%
60.4%
0.0%
60.7%
0.0%

%
Estimated
12.5%
14.3%
74.7%
14.0%
74.7%

%
Missing
25.3%
25.3%
25.3%
25.3%
25.3%

Vendor-Based
Industry-Based

Exposure to Fossil Fuels(% of MV)
20.2%
17.0%

%
Missing
8.5%
0.0%

Notes:
Except where noted, the data above is sourced from MSCI. Where data is shown as “reported” this is based on MSCI’s indication that the data has
been reported by the relevant issuer. Except in certain cases where noted (see the final note below), where data is shown as “estimated” this is basedon MSCI’s estimation models. MSCI is a widely recognised ESG data vendor, however the Firm makes no further representations or assurances
about the quality or accuracy of the data provided by MSCI.
- Data was extracted and compiled as of the Calculation Date. However, data for individual issuers underlying the combined figures shown above is
as of the most recent date prior to the Calculation Date that MSCI had collected data for that issuer or calculated its estimated emissions, asapplicable. This varies by issuer, and is generally prior to the Calculation Date.
- For Weighted Average Carbon Intensity, data is available at both the individual scope 1 and 2 levels, and at the scope 1&2 combined level. In cases
where both are available, for scope 1&2 metrics, we use the combined-level data. At times there are slight differences between individual scope dataand combined scope data (likely due data being as of different dates), so individual scope numbers do not always add to the combined value.
- Scope 3 data is always estimated. When companies report scope 3, it is their estimate. For consistency, we use data vendor estimates in all cases.
- Absolute GHG Emissions are calculated by scaling the Carbon Footprint figures based on portfolio size. This may result in very slight differences
versus attributing emissions to the portfolio at the issuer level and then summing, but normally this should not be material.
- The vendor-based fossil fuel exposure figures rely on MSCI’s “fossil fuels – any tie” flag. The industry-based fossil fuel exposure figures include
any issuer in the electric utility, metals and mining or oil & gas industries (based on Barclays industry classifications), which may include issuersthat do not currently have any actual exposure to fossil fuels. Therefore the industry-based figures are usually more conservative. In all cases, data is
assumed available if the data vendor rates the issuer (and missing otherwise).
* Figures in the “Scope 1 & 2 with PGIM Fixed Income Estimates” row are based first on data from MSCI. For issuers where this data isn't available, anestimate is used that is generally based on MSCI data for other issuers in the same industry. These estimates are designed to be conservative (i.e. they
are more likely to result in an overestimate of emissions than an underestimate), however they can be highly imprecise. There may be cases where an
issuer's actual emissions are materially different from the PGIM Fixed Income estimate.

-

SOVEREIGN ISSUERSNOTE: All metrics in the section below only apply to sovereign issuers. Values are scaled to the size of the sovereign
sleeve of the Portfolios, which comprises 23.7% of the total AUM in the Portfolios.
Average GHG Intensity of GDP(tCO2e / Nominal USD 1M)
654

Average GHGs Per Capita(tCO2e pc)
10.1% with GHGs Per Capita >=15tCO2e22.2%% Missing GHG
Intensity
0.0%% Missing GHG
Per Capita
0.0%

Notes:-

Except where noted, the data above is sourced from MSCI. MSCI is a widely recognised ESG data vendor, however the Firm makes no further
representations or assurances about the quality or accuracy of the data provided by MSCI.
Data was extracted and compiled as of the Calculation Date. However, data for individual issuers underlying the combined figures shown above is
as of the most recent date prior to the Calculation Date that MSCI had collected data for that issuer or calculated its estimated emissions, asapplicable. This varies by issuer, and is generally prior to the Calculation Date.
GHG Intensity of GDP is generally calculated based on the PCAF methodology. However, they are based on nominal GDP here (not PPP adjusted)
and include only territorial emissions.

(c) Targets used by the Firm to manage climate-related risks and opportunities and performance against targets
This sub-section of the Report summarises targets used by the Firm to manage climate-related risks andopportunities.
A climate-related target is a commitment, which may be imposed by an investment manager or an end client on a managed
portfolio, relating to particular climate metrics. In the UK, there is not a regulatory requirement for investment firms to
PGIM Fixed Income  PGIM Limited 2023 FCA TCFD Disclosures—Entity Level10

impose climate-related targets and the Firm does not impose such targets on any Portfolio that it manages unless explicitly
directed to do so in that Portfolio’s investment guidelines.
The Firm manages certain Portfolios which expressly include climate-related targets set by clients in those Portfolios. In
some (but not all) cases, such Portfolios include in the investment guidelines for the relevant product or service an express
commitment to meet the relevant target.
However, the Firm does not impose climate-related targets on a blanket basis across all of its managed Portfolios.
For those Portfolios for which the Firm has not integrated an express climate-related target, this is because the Firm would
require the express agreement of its clients to integrate a climate-related target into the management of Portfolios. At thedate of this Report, there is no instruction in respect of the climate-related target for those out-of-scope Portfolios.

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