(k) Funds that obtain exposure to ESG-related investments indirectly
Where an ESG Objective Fund’s investment objectives state that the fund will primarily invest in investments that are ESG-related (as determined by the ESG focus(es) of the fund) or that meet certain ESG-related criteria, but also state that the fund may meet this objective through indirect investments or by investing in companies with indirect exposure to such investments, the investment strategies should explain the nature of the indirect investments or exposure and how such indirect investments or exposure help the fund meet its ESG-related investment objectives.
(l) Funds whose names and/or investment objectives include the term “impact”
In order to avoid greenwashing, staff’s view is that if a fund’s name and/or investment objectives include the term impact, the investment strategies disclosure should explain what type of impact the fund is aiming to achieve, since the term impact, w hen used in the context of ESG investing, is generally understood to be a reference to impact investing.