(2)(a-b) of the UCITS Directive and Article 4

(1)(

1. a)of the AIFM Directive); Fund Managers
2. a)a management company (

(1)(

1. b)of the UCITS Directive);
2. b)an investment company that has not designated a management company authorised pursuant to the UCITS Directive;
3. c)an AIFM (

(1)(

1. b)of the AIFMD) of an AIFs; and
2. d)an internally managed AIF in accordance with Article 5

(1)(b) of the AIFMD

1. Purpose
2. These guidelines are based on Article 23

(7)of the AIFMD, Article 69

(6)of the UCITS Directive and Article 16

(1)of the ESMA Regulation. The purpose of these guidelines is to specify the circumstances where the fund names using ESG or sustainability related terms are unfair, unclear or misleading.

1. The name of a fund is a means of communicating information about the fund to investors and is also an important marketing tool for the fund. A fund’s name is often the first piece of fund information investors see and, while investors should go beyond the name itself and look closely at a fund’s underlying disclosures, a fund’s name can have a significant impact on their investment decisions.
2. Compliance and reporting obligations 4.1 Status of the guidelines
3. In accordance with Article 16

(3)of the ESMA Regulation, competent authorities and financial market participants must make every effort to comply with these guidelines. 10. Competent authorities to which these guidelines apply should comply by incorporating them into their national legal and/or supervisory frameworks as appropriate, including where particular guidelines are directed primarily at financial market participants. In this case, competent authorities should ensure through their supervision that financial market participants comply with the guidelines. 6 4.2 Reporting requirements 11. Within two months of the date of publication of the guidelines on ESMA’s website in all EU official languages, competent authorities to which these guidelines apply must notify ESMA whether they (

1. i)comply, (
2. ii)do not comply, but intend to comply, or (iii) do not comply and do not intend to comply with the guidelines. 12. In case of non-compliance, competent authorities must also notify ESMA within two months of the date of publication of the guidelines on ESMA’s website in all EU official languages of their reasons for not complying with the guidelines. 13. A template for notifications is available on ESMA’s website. Once the template has been filled in, it shall be transmitted to ESMA. 14. Financial market participants are not required to report whether they comply with these guidelines. 5. Guidelines on funds’ names using ESG or sustainabilityrelated terms in UCITS and AIF names 5.1 Explanations of key terms under these Guidelines 15. The following explanations are relevant for the key terms mentioned in the below sections of these Guidelines. - “Transition”-related terms encompass any terms derived from the base word “transition”, e.g. “transitioning”, “transitional” etc. and those terms deriving from “improve”, “progress”, “evolution”, “transformation”, “net-zero”, etc. - “Environmental”-related terms mean any words giving the investor any impression of the promotion of environmental characteristics, e.g., “green”, “environmental”, “climate”, etc. These terms may also include “ESG 10” and “SRI 11” abbreviations. - “Social”-related terms mean any words giving the investor any impression of the promotion of social characteristics, e.g., “social”, “equality”, etc. - “Governance”-related terms mean any words giving the investor any impression of a focus on governance, e.g., “governance”, “controversies”, etc. 10 11 “ESG” means Environmental, Social, Governance “SRI” means Socially Responsible Investments 7 - “Impact”-related terms mean any terms derived from the base word “impact”, e.g., “impacting”, “impactful”, etc. - “Sustainability”-related terms mean any terms only derived from the base word “sustainable”, e.g., “sustainably, “sustainability” etc. 5.2 Recommendations to fund managers on the use of terms in funds’ names 16. Funds using transition-, social- and governance-related terms should: - meet an 80% threshold linked to the proportion of investments used to meet environmental or social characteristic or sustainable investment objectives in accordance with the binding elements of the investment strategy, which are to be disclosed in Annexes II and III of CDR (EU) 2022/1288; and - exclude investments in companies referred to in Article 12

(1)(

1. a)to (
2. c)of CDR (EU) 2020/1818. 17. Funds using environmental- or impact-related terms should: - meet an 80% threshold linked to the proportion of investments used to meet environmental or social characteristic or sustainable investment objectives in accordance with the binding elements of the investment strategy, which are to be disclosed in Annexes II and III of CDR (EU) 2022/1288; and - exclude investments in companies referred to in Article 12

(1)(

1. a)to (
2. g)of CDR (EU) 2020/1818. 18. Funds using sustainability-related terms should: - meet an 80% threshold linked to the proportion of investments used to meet environmental or social characteristic or sustainable investment objectives in accordance with the binding elements of the investment strategy, which are to be disclosed in Annexes II and III of CDR (EU) 2022/1288; 8 - exclude investments in companies referred to in Article 12

(1)(

1. a)to (
2. g)of CDR (EU) 2020/1818; and - commit to invest meaningfully in sustainable investments referred to in Article 2

(17)of the SFDR.

1. Where a Fund name combines terms from more than one of paragraphs 16 and 17, the provisions of those paragraphs should apply cumulatively, except for those terms combined with any transition-related terms, where only paragraphs 16 and 21 should apply. Further recommendations for specific type of funds
2. Funds designating an index as a reference benchmark should only use the terms as referred to in paragraphs 16 to 18 in their name if the guidance under those paragraphs are fulfilled by the Fund.
3. Funds using “transition-” or “impact”-related terms in their names should also ensure that investments used to meet the threshold referred to in paragraphs 16 and 17 respectively are on a clear and measurable path to social or environmental transition or are made with the objective to generate a positive and measurable social or environmental impact alongside a financial return. Supervisory expectations
4. Competent authorities should consider paragraphs 16 to 21 throughout the life of the Fund. Investors could verify this information through the periodic disclosures provided in accordance with the CDR (EU) 2022/
5. A temporary deviation from the threshold and the exclusions, should be treated as a passive breach and corrected in the best interest of the investors, provided that the deviation is not due to a deliberate choice by the Fund Manager.
6. Subject to the relevant circumstances, competent authorities should consider that inputs warranting further investigation and a supervisory dialogue with the Fund Manager include the following: 9 - Discrepancies in the level of the quantitative threshold which are not passive breaches; - A Fund that does not demonstrate sufficiently high level of investments to use transition-, ESG-, impact- or sustainability-related terms in its name; or - Where the competent authority considers that using transition-, ESG-, impact- or sustainability-related terms in the Fund name would result in investors receiving unfair or unclear information or in a failure of the manager to act honestly or fairly thus misleading investors. 10