Barings ASEAN Frontiers Fund
SUMMARY
The Fund will seek to achieve its investment objective by investing at least 70% of its Net Asset Value at
any one time in equities and equity-related securities of issuers incorporated in, or exercising thepredominant part of their economic activity in, countries which are members of the Association of SouthEast Asian Nations (ASEAN) or quoted or traded on the stock exchanges in those countries. The membersof ASEAN include (but not to be limited to) Singapore, Thailand, the Philippines, Malaysia, Indonesia andVietnam.
This Fund promotes environmental or social characteristics but does not have as its objective sustainable
investment. The Fund will invest at least 50% of the Fund’s Net Asset Value in equities of issuers thatexhibit positive or improving environmental ("E"), social ("S") and governance (“ESG”) characteristics. The
E and S evaluations are established using proprietary research based on issuer knowledge and regularmanagement interaction. For all investment opportunities, a thorough ESG assessment is conducted using
a proprietary scorecard of nine ESG topics, and a quality score, management score, and ESG cost ofequity ("CoE") adjustment is assigned to each investment. The Fund does not have a reference benchmarkthat has been designated for the purpose of attaining the environmental or social characteristics promoted
by Fund.
The Fund's remaining 50% will comprise assets (including cash, cash equivalents, hedging instruments
and other assets) which are neither aligned with the environmental or social characteristic, have no
minimum environmental or social safeguards, nor are qualified as sustainable investments. The Fund may
also invest up to 50% of its Net Asset Value in equities and equity related securities of issuers that exhibit
less positive ESG characteristics.
Derivatives are not used to attain the environmental or social characteristics promoted by the Fund and theFund does not use a reference benchmark to measure the attainment of its environmental and social
characteristics.
The Fund may invest in various FDIs for investment purposes or for efficient portfolio management
including investment in FDI on commodity indices. When FDIs are used the Fund will be leveraged throughthe leverage inherent in the use of FDIs.
The Fund adheres to the investment restrictions required to qualify as "equity fund" pursuant to section 2
paragraph 6 GITA and continuously invests more than 50% of its Net Asset Value in equity participations
within the meaning of section 2 paragraph 8 GITA.
The Investment Manager believes that equity markets contain unrecognised growth potential and seeks to
identify this through the analysis of an issuers business model whilst incorporating wider ESG trends often
referred to as fundamental analysis. ESG trends may evolve over time and may include environmental
footprint, societal impact of products/services and effectiveness of supervisory/management boards. Equity
investment teams at the Investment Manager share a common investment approach, best described as
Growth at a Reasonable Price (“GARP”).

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Issuers that exhibit positive or improving ESG characteristics are assessed through the Investment
Manager’s proprietary research. This assessment is captured within a standardised framework, and is
dynamic, monitoring the attitudes of issuers for improvements or deteriorations toward ESG topics andreflected in the scoring of an issuer’s quality and its valuation. With respect to issuer valuations, theInvestment Manager’s approach allows for ESG research to directly affect the discount rate (Barings Costof Equity) applied to its 5-year earnings and dividend forecast for the issuer. By explicitly quantifying the
ESG impact on the valuation of investee issuers, ESG is integrated into decision-making, issuer selection
and the management of the portfolio.
The Fund has implemented a binding constraint into its investment policy that allocates at least 50% of its
Net Asset Value in equities of issuers that exhibit positive or improving environmental, social andgovernance characteristics.
The sustainability indicator used to measure the attainment of the environmental and social characteristics
promoted by the Fund will be the percentage of the Fund’s Net Asset Value invested in equities of issuersthat exhibit positive or improving ESG characteristics. Issuers defined as having positive or improving ESG
charateristics must be assessed as having a higher than average quality score, and not exceed amaximum adjustments to its Barings Cost of Equity threshold. Pre- and post-trade checks are carried out
on a daily basis to ensure the Fund continues to meet the minimum threshold of 50%. Where the Fund falls
below this threshold, due to market movements or because the issuers it holds no longer meet the criteriaof a “green” investment, then the passive breach will be corrected at the earliest opportunity.
The Investment Manager also adopts an active management policy in relation to ESG topics and has apreference to focus on engagement to improve issuer behaviour.
The Investment Manager's investment decisions are based on internal research, which encompass both its
proprietary financial forecasts and ESG assessment. The Investment Manager aims to meet with all issuers
in which it seeks to invest at least annually and discuss a range of topics including ESG issues withmanagement. The investment professional within the Investment Manager responsible for evaluating theissuer is also responsible for its ESG assessment: this is an integral part of its analysis. In addition to theInvestment Manager’s in-house evaluation of ESG risks, it also has access to third party resources thatprovide ESG information.
In evaluating an investment, the Investment Manager is dependent upon information and data, which may
be incomplete, inaccurate or unavailable. The inconsistent quality, availability and timeliness of ESG data
presents both a challenge and an opportunity for the investment professionals within the Investment
Manager. Interacting directly with issuers allows the Investment Manager to generate its own insights andexploit such market inefficiencies, whilst attempting to mitigate the risks that come with them.

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NO SUSTAINABLE INVESTMENT OBJECTIVE
This Fund promotes environmental or social characteristics but does not have as its objective sustainable
investment.

ENVIRONMENTAL OR SOCIAL CHARACTERISTICS OF THE FINANCIAL
PRODUCTThe environmental and social characteristics promoted by the Fund will be to invest at least 50% of its Net
Asset Value in equities of issuers that exhibit positive or improving environmental, social and governance(“ESG”) characteristics.
The E and S evaluations are established using proprietary research based on issuer knowledge andregular management interaction. For all investment opportunities, a thorough ESG assessment isconducted using a proprietary scorecard of nine ESG topics, and a quality score, management score, and
ESG cost of equity ("CoE") adjustment is assigned to each investment.
The Fund does not have a reference benchmark that has been designated for the purpose of attaining theenvironmental or social characteristics promoted by Fund.

INVESTMENT STRATEGYa.) Investment strategy
The Fund will seek to achieve its investment objective by investing at least 70% of its Net Asset Value at
any one time in equities and equity-related securities of issuers incorporated in, or exercising thepredominant part of their economic activity in, countries which are members of the Association of SouthEast Asian Nations (ASEAN) or quoted or traded on the stock exchanges in those countries. The membersof ASEAN include (but not to be limited to) Singapore, Thailand, the Philippines, Malaysia, Indonesia andVietnam.
The Fund will invest at least 50% of the Fund’s Net Asset Value in equities of issuers that exhibit positive or
improving ESG characteristics. Furthermore, the Fund may also invest up to 50% of its Net Asset Value inequities and equity related securities of issuers that exhibit less positive ESG characteristics.
The Fund may also invest up to 30% of its Net Asset Value, either directly or through depositary receipts, inequities and equity-related securities of issuers that are (i) incorporated, or (ii) exercising the predominantpart of their economic activity, or (iii) quoted or traded on the stock exchanges, in (a) other markets in the
Asia Pacific region including, but not limited to, Korea, Hong Kong, China, Taiwan, India, Australia, New
Zealand, Pakistan, Sri Lanka and Bangladesh but excluding Japan, or (b) other markets which theManager believes would have the potential to benefit from the economic growth and development from theAsia Pacific region excluding Japan, when and if they consider it appropriate.
The Fund may also invest in collective investment schemes in accordance with the requirements of theCentral Bank up to a maximum of 10% of the Net Asset Value of the Fund.
With regard to investment in China, no more than 20% of the Net Asset Value of the Fund at any one time
may be invested directly or indirectly in China A shares and B shares. It is anticipated that this exposure
will be obtained either directly through investment in China A shares listed on the Shanghai Stock

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Exchange and Shenzhen Stock Exchange via the Connect Schemes and/or through the QFI regime orindirectly through investment in other eligible collective investment schemes or participation notes.
The Fund may invest in various FDIs as detailed under the section headed “Investment Policy: General” forinvestment purposes or for efficient portfolio management in accordance with the requirements of theCentral Bank. When FDIs are used the Fund will be leveraged through the leverage inherent in the use of
FDIs.
The Fund adheres to the investment restrictions required to qualify as "equity fund" pursuant to section 2
paragraph 6 GITA and continuously invests more than 50% of its Net Asset Value in equity participations
within the meaning of section 2 paragraph 8 GITA.
The Investment Manager believes that equity markets contain unrecognised growth potential and seeks to
identify this through the analysis of an issuer’s business model whilst incorporating wider ESG trends often
referred to as fundamental analysis. ESG trends may evolve over time and may include environmental
footprint, societal impact of products/services and effectiveness of supervisory/management boards. Equity
investment teams at the Investment Manager share a common investment approach, best described as
Growth at a Reasonable Price (“GARP”).
GARP seeks to identify reasonably priced growth issuers whose qualities are unrecognised by market
participants by performing structured fundamental analysis with a disciplined investment process. Based on
the region, country or sector bias of the Fund, analysis of potential growth issuers’ includes their futurefinancial performance as well as their business model and management style, while focussing on long-term
earnings growth of three to five years. The Investment Manager values issuers utilising proprietaryvaluation models that incorporate ESG analysis and macro considerations.
The Investment Manager’s strategy favours issuers with sustainable or improving business franchises,
profitability focused management and strong balance sheets that enable the issuer to execute its businessstrategy. The Investment Manager regards these issuers as higher quality as they provide transparency
and allow investment professionals to forecast earnings with greater confidence. This is further
strengthened through the incorporation of a dynamic and forward-looking approach to ESG analysis, withthe aim to identify sustainable business practices. This empowers the Investment Manager to better assess
both the potential risks facing the issuer and the opportunities presented to it, particularly those notapparent or included in traditional fundamental analysis, and facilitates in propagating better ESG
practices. The Investment Manager believes that ESG integration, a focus on forward-looking dynamics
and active engagement is key to unlocking long-term returns in equity investments.
Issuers that exhibit positive or improving ESG characteristics are assessed through the Investment
Manager’s proprietary research. Proprietary research is based on issuer knowledge and regularmanagement interaction, which is the basis to assess each issuer against nine key ESG topics:•

Employee Satisfaction;•

Resource Intensity;•

Traceability and/or Security in Supply Chain;•

Effectiveness of Supervisory and/or Management Board;•

Credibility of Auditing Arrangements;

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•Transparency and Accountability of Management;•

Environmental Footprint;•

Societal Impact of Products and/or Services; and•Business Ethics.

This assessment is captured within a standardised framework, and is dynamic, monitoring the attitudes ofinvestee issuers for improvements or deteriorations toward ESG topics and reflected in the scoring of anissuer’s quality and its valuation. With respect to issuer valuations, the Investment Manager’s approachallows for ESG research to directly affect the discount rate (Barings Cost of Equity) applied to its 5-year
earnings and dividend forecast for the issuer. By explicitly quantifying the ESG impact on the valuation of
investee issuers, ESG is integrated into decision-making, issuer selection and the management of theportfolio.
This approach enables the Investment Manager to rate issuers on the basis of their dynamic ESG
behaviour rather than making a static judgement based on historical ESG practices and is consistent withforward looking analysis and the intention to reward progress and improvement. Before investing, theInvestment Manager considers internal recommendations regarding growth, quality and valuation, all ofwhich reflect ESG issues and opportunities, alongside external issuer-specific data. Once invested, theInvestment Manager continues to monitor each issuer to ensure that the thesis remains intact and that an
investment’s risk and return profile remains attractive relative to other opportunities available in the market.
The Fund has implemented a binding constraint into its investment policy that allocates at least 50% of its
Net Asset Value in equities of issuers that exhibit positive or improving environmental, social andgovernance characteristics.
For all investment opportunities, thorough ESG assessment is conducted using a proprietary scorecard ofnine ESG topics, and a quality score, management score, and ESG CoE adjustment is assigned to each
investment.
1.
Quality Score – The quality score is a rating from 1 to 5 (1 = strong, 5 = weak), which is anexpression of the Investmetn Manager's evaluation of an issuer’s franchise, management, and balance
sheet.
2.
Management Score – The management score, which also carries a rating of 1 to 5 (1 = strong, 5 =weak), is an expression of the Investment Manager's evaluation of the strength of the issuer’s management
and corporate governance. Issuers with sound management structures, diverse and accessible executive
teams, and remuneration policies aligned with the long-term interests of minority shareholders would
generally be assigned a stronger management score.
3.
ESG CoE Adjustment - Finally, each of the nine ESG topics in the proprietary scorecard is rated as
one of the following: Exemplary, Improving, Not Improving, or Unfavourable. The sum of the nine ratingscorresponds with an ESG discount or premium, which is added to the CoE. The CoE is the rate of return
required from the issuer by the Investment Manager. An Exemplary rating will result in an ESG reduction to
the issuer’s CoE. Conversely, an Unfavourable or Not Improving rating will result in an ESG addition to theissuer’s CoE.

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Pre- and post-trade checks are carried out on a daily basis to ensure the Fund continues to meet theminimum threshold of 50%.

Issuers defined as having positive or improving ESG characteristics must have a higher than average
quality score, and not exceed a maximum adjustment to its Barings Cost of Equity threshold. The
Investment Manager also requires that such issuers have good corporate governance, internally assessedwith respect to, but not limited to, sound management structures and tax compliance.
The Investment Manager also believes that it can use its influence to effect positive change and improve
ESG disclosure through active engagement with investee issuers. These formal engagements areundertaken to influence (or identify the need to influence) ESG practices and/or improve ESG public
disclosure, which in the opinion of the Investment Manager, is material to the sustainability of the issuer’s
business model, aiming to enhance the performance of investments.
b.) Policy to assess good governance practices of the investee issuers
The Investment Manager assesses the corporate governance of issuers, with respect to, but not limited to,sound management structures, employee relations, remuneration of staff and tax compliance. An internalmanagement score ranging from 1 (strong) to 5 (weak) is assigned. Issuers which have a managementscore of 5 are excluded from the fund. Where the Investment Manager determines that a holding in the
Fund's portfolio does not meet its good governance thresholds, the Investment Manager will engage withthe relevant issuer in order to seek to bring it into compliance. If engagement with the relevant issuer is notdeemed appropriate or engagement subsequently proves unsuccessful, the Investment Manager willconsider its position and shall, if necessary and to the extent possible based upon market conditions andany specific investment considerations, attempt to divest the holding from the Fund.

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PROPORTION OF INVESTMENTS
The Fund will invest at least 50% of its Net Asset Value in equities of issuers that exhibit positive or
improving ESG characteristics. whilst the remaining assets (including cash, cash equivalents, hedging
instruments and other assets) which are not aligned with the Fund's E and/or S characteristics and/or haveno minimum environmental or social safeguards.
The Fund may also invest up to 50% of its Net Asset Value in equities and equity related securities ofissuers that exhibit less positive ESG characteristics.
Derivatives are not used to attain the environmental or social characteristics promoted by the Fund.

MONITORING OF ENVIRONMENTAL OR SOCIAL CHARACTERISTICS
The sustainability indicator used to measure the attainment of the environmental and social characteristics
promoted by the Fund will be the percentage of the Fund’s Net Asset Value invested in equities of issuersthat exhibit positive or improving ESG characteristics. Issuers defined as having positive or improving ESG
charateristics must be assessed as having a higher than average quality score, and not exceed amaximum adjustments to its Barings Cost of Equity threshold.
The Fund is monitored on each business day to ensure it continues to meet the minimum threshold of 50%.
Where the Fund falls below this threshold, due to market movements or because the issuers it holds nolonger meet the criteria of a “green” investment, then the passive breach will be corrected at the earliest
opportunity.

METHODOLOGIESThe Fund will invest at least 50% of its Net Asset Value in equities of issuers that exhibit positive or
improving ESG characteristics.
Issuers the Fund invests in are classified as either:•“Green” – by exhibiting “Positive” or “Improving” ESG characteristics; or•“Brown” – by not meeting the criteria illustrated below.

The below tables illustrate the criteria used to classify issuers

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Investments with a Quality Score of more than 3 or Management Score of more than 2.5 or ESG CoEadjustment of more than 1% will always be considered as “brown”.
The criteria the Investment Manager uses to determine if an issuer exhibits positive or improving ESG
characteristics are described below. A full explanation of the criteria can be found in the Investment
Manager's Public Equities: ESG Integration and Active Ownership policy.
Quality Score
The Quality Score is a rating from 1 to 5 (1 = strong, 5 = weak), which is an expression of the Investment
Manager's evaluation of an issuer’s:• Franchise;• Management; and• Balance Sheet
Each of these categories is assessed under nine ESG topics – as set below:

Management Score
Three of the nine key topics (4, 5 and 6) focus specifically on assessing the issuer’s management. The
Management Score, which also carries a rating of 1 to 5 (1 = strong, 5 = weak), is an expression of theInvestment Manager's evaluation of the strength of the issuer’s management and corporate governance.

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Issuers with sound management structures, diverse and accessible executive teams, and remuneration
policies aligned with the long-term interests of minority shareholders would generally be assigned astronger Management score.
ESG CoE Adjustment
Finally, each of the nine key topics outlined above are rated as one of the following:••••

Exemplary
ImprovingNot Improving
Unfavourable

Each key topic is rating is equally weighted. The average of the nine assessments corresponds with an
ESG discount or premium, which is added to the cost of equity (“CoE”). The CoE is the rate of return
required from the issuer by the Investment Manager. An Exemplary rating will result in an ESG reduction to
the issuer’s CoE. Conversely, an Unfavourable or Not Improving rating will result in an ESG addition to theissuer’s CoE.

DATA SOURCES AND PROCESSINGa)the data sources used to attain the fund’s environmental and social characteristics;

The Investment Manager's investment decisions are based on internal research, which encompass both its
proprietary financial forecasts and ESG assessment. The Investment Manager aims to meet with all issuers
in which it seeks to invest at least annually and discuss a range of topics including ESG issues withmanagement.
Use of external sources of research remains limited and are utilised to mainly understand market
consensus and as one of the ways to gather data. To supplement the Investment Manager's own ESG
research, it also has access to third-party resources such as Bloomberg ESG, MSCI ESG and
Sustainalytics, which provide institutional investors with issuer-specific ESG data.
b) the measures taken to ensure data quality;
The Investment Manager looks to gather information from multiple sources, which include directinteractions with issuers and utilising multiple third-party research datasets. This allows the Investment
Manager to create a fuller picture of an issuer’s ESG dynamics, gain insight on its practices and assess
data quality and consistency.
The Investment Manager does not rely on third party research providers’ conclusions to make investment
decisions. The Investment Manager merely uses their research as one way to access data and as achallenge mechanism to its own views.
c)how data are processed; andThe investment professional responsible for evaluating and valuing the issuer in the Investment Manager isalso responsible for the ESG assessment: this is an integral part of the Investment Manager's analysis.

BARINGS ASEAN FRONTIERS FUNDBARINGS.COM | 9d) the proportion of data that are estimated.
The Investment Manager uses data from multiple data sources, including from direct interactions withissuers, financial statements and external ESG data providers. There may be instances where theInvestment Manager may perform internal calculations of ESG metrics to obtain a fuller understanding of
an issuer's ESG performance and to enable comparison between issuers.

LIMITATIONS TO METHODOLOGIES AND DATAa)any limitations to the methodologies referred to in “METHODOLOGIES” and “DATASOURCES AND PROCESSING”; andThe inconsistent quality, availability and timeliness of ESG data presents both a challenge and an
opportunity for the Investment Manager's investment professionals. Interacting directly with issuers allows
the Investment Manager to generate its own insights and exploit such market inefficiencies, whilst
attempting to mitigate the risks that come with them.
b) how such limitations do not affect how the fund’s environmental and social characteristics
are met.]Many ESG considerations are challenging to assess quantitatively, making the judgement of investment
professionals within the Investment Manager key. The Investment Manager looks to gather informationfrom multiple sources, which include direct interactions with issuers and utilising multiple third-party
research datasets. This allows the Investment Manager to create a fuller picture of an issuer’s ESG
dynamics, gain insight on its practices and asssess data quality and consistency.

DUE DILIGENCE
The Fund is monitored by Barings Guideline Management team, which is part of the Compliance function,
on each business day to ensure it continues to meet the minimum threshold of 50%. Where the Fund falls
below this threshold, due to market movements or because the issuers it holds no longer meet the criteriaof a “green” investment, then the passive breach will be corrected at the earliest opportunity.
In addition, prior to each trade, the Investment Manager ensures that the trade will not lead to the Fundfalling below the 50% threshold and if so, the trade will be stopped and the portfolio manager in theInvestment Manager will be notified.

ENGAGEMENT POLICIESThe Investment Manager applies the PRI’s definition of engagement, which is “…Interactions between an
investor (or an engagement service provider) and current or potential investees (e.g., issuers), conductedwith the purpose of improving practice on an ESG issue, changing a sustainability outcome, or improving
public disclosure.” Engagements can also be carried out with non-issuer stakeholders, such aspolicymakers or standard setters.
Engagements are undertaken to influence (or identify the need to influence) ESG practices and/or improve
ESG disclosure. Through engagement, the Investment Manager aims to enhance the performance of its
investments, for the benefit of its clients in line with its stewardship responsibility. The Investment Manager
does not, however, attempt to impose an inflexible approach that ignores local norms and contexts. The
Investment Manager believes that value is derived from transparent communication with the issuers inwhich it invests, coupled with the expertise and discretion of its experienced analysts and portfolio

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managers, and that a one-size-fits-all approach should not and cannot be applied across the wide range ofassets that it manages across the globe.
A full explanation of the Engagement Policy can be found in the Investment Manager's Public Equities: ESG
Integration and Active Ownership policy.

DESIGNATED REFERENCE BENCHMARKThe Fund does not use a reference benchmark to measure the attainment of its environmental and social
characteristics.

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