EU ESG Ratings Regulation Disclosures | Insight Investment

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Disclosures

Rating Product Disclosures

The objective of the Corporate ESG Ratings is to identify and assess financially material environmental, social and governance risks faced by corporate issuers. The ratings are designed to support investment decision making and engagement by highlighting ESG risks that may affect creditworthiness and short- to medium-term financial performance. The rating assesses ESG risks only and does not assess impacts; corporate impact on society or the environment is not explicitly assessed.

The ratings cover environmental, social and governance (E, S and G) pillars. Scores are produced at ESG issue level, which are aggregated into pillar scores and then into an overall ESG rating. The scope therefore includes both pillar-level and aggregated ESG assessment. As the rating is intended to provide an overall ESG risk profile of companies, specific issues such as transition risks are not individually assessed.

ESG issue-level scores are weighted according to their financial materiality for each industry. Different ESG issues receive different weights depending on their relevance to the industry in which the company operates. These scores are aggregated into theme and pillar scores, which are then combined to produce an overall ESG rating. There is no fixed or universal weighting between E, S and G pillars; weightings vary by sector.

The topics covered are:

• Environmental: Climate change, natural capital and pollution
• Social: Customers and communities, products and workforce
• Governance: Corporate governance, behaviour and macro

The topics broadly correspond to those included in sustainability reporting standards developed under Article 29b (ESRS). However, they represent a subset focused on financially material ESG risks in the context of credit assessment.

The ratings are expressed on a relative basis, assessing a company’s ESG risk profile in comparison with its industry peers.

The ratings do not explicitly assess alignment with the Paris Agreement or other international environmental agreements.

The ratings do not explicitly assess alignment with international social or governance agreements. However, where practical and relevant, the methodology takes into account the standards of the Sustainability Accounting Standards Board (SASB).

General Methodological Disclosures

The ratings use a structured analytical approach combining multiple third-party ESG data inputs with internal weighting methodologies, including analyst assessments. The methodology focuses primarily on backward-looking indicators of ESG risk based on disclosed policies, practices and controversies, while incorporating forward-looking elements where available (such as risk management and mitigation efforts). The ratings reflect ESG risks over a near- to medium-term investment horizon. The methodologies are not generally based on scientific evidence.

An internal industry classification relevant to the fixed income asset class is used.

The methodology draws on multiple external ESG data providers, using a combination of publicly available information and proprietary third-party datasets. Data may include sustainability statements required under the CSRD and disclosures under SFDR. Data inputs are reviewed for relevance and quality and combined using internal weightings.

Ratings are generally updated quarterly or as otherwise determined. Where data gaps exist, these are identified and may be supplemented or estimated through proprietary company surveys, qualitative assessments or engagement with issuers.

The methodology is not explicitly derived from academic research nor generally based on scientific evidence.

Insight Investment does not rely on autonomous artificial intelligence (“AI”) systems for ESG rating creation or maintenance; automated tools may be used to support data collection, processing and/or aggregation, but are subject to appropriate human oversight and governance controls. Nevertheless, there can be no assurance or guarantee that such tools will perform as designed or as intended. If the models or data utilised by such tools are incorrect or incomplete, any decisions made in reliance thereon may lead to inaccurate ratings. The use of such tools has inherent risks. For example, such tools may incorrectly forecast future behaviour, leading to inaccurate ratings. Lastly, the regulatory landscape for AI, data privacy and algorithmic processing is developing rapidly across jurisdictions.  New or amended rules could impose additional controls or constrain certain techniques.  Compliance adaptations may be implemented without notice and may affect related processes, timing or outcomes.

Limitations in data sources, methodologies and information

The ratings are subject to limitations arising from ESG data availability, quality and comparability. They rely on third-party data which may be incomplete, inaccurate or inconsistent. The methodology is designed as a best-in-class framework and is therefore not suitable for cross-sector comparability or best-in-universe assessments.

There are limitations in the availability of ESG information, including gaps in issuer disclosures and inconsistencies across data providers. Where data is unavailable, estimates or qualitative assessments may be applied, which may affect the accuracy of the ratings.

Organisational Disclosures

IIMEL is a wholly owned subsidiary of Insight Investment Management Limited, the ultimate holding company of which is The Bank of New York Mellon Corporation.

The ESG ratings are not sold on a standalone issuer-paid basis. Insight Investment is not specifically remunerated for the provision of ESG ratings. Fees charged to clients relate to broader investment management and related services rather than ESG ratings.

IMEL has established and maintains an effective conflict of interest policy which incorporates procedures seeking to identify, prevent, manage and monitor any conflicts of interest in relation to Insight ESG ratings. There may be potential conflicts of interest that Insight ESG ratings may be influenced through the use of supplementary data inputs and/or manual adjustments, resulting in a rating that differs from the standard model output. Such risks are sought to be mitigated through the application of consistent quantitative methodologies, oversight, appropriate approval of any overrides and monitoring. The above disclosures are illustrative only and do not purport to be a complete enumeration or explanation of all of the conflicts of interest that may be involved in relation to Insight ESG ratings.

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Disclosures

Rating Product Disclosures

The objective of the Municipal ESG Ratings is to identify and assess financially material environmental, social and governance risks faced by municipal issuers. The ratings are designed to support investment decision making and engagement by highlighting ESG risks that may affect creditworthiness and short- to medium-term financial performance. The rating assesses ESG risks only; municipal impact on society or the environment is not explicitly assessed.

The ratings cover environmental, social and governance (E, S and G) pillars. Scores are produced for individual ESG issues within each of those pillars, which are then aggregated into environmental, social and governance pillar scores based on the relevance of each ESG issue for that specific industry.

ESG issue-level scores are weighted according to their financial materiality for each industry. Different ESG issues receive different weights depending on their relevance to that industry. These issue-level scores are aggregated into theme and pillar scores, which are then combined to produce an overall ESG rating. Because the weightings depend on the industry, there is no fixed or universal weighting between E, S and G pillars; weighting varies by sector.

The topics covered are:

• Environmental: Physical risk, climate change, natural capital and pollution
• Social: Health, communities and access
• Governance: Structure, transparency and risk management

The topics covered by the Municipal ESG ratings do not explicitly correspond to those in the sustainability reporting standards developed under Article 29b (the ESRS), as these standards do not apply to municipal issuers. However, there is some thematic alignment, as they reflect a subset focused on financially material ESG risks for credit assessment.

The ratings are expressed on a relative basis, assessing a municipal issuer’s ESG risk profile in comparison with its industry peers rather than as an absolute score.

The ratings do not explicitly assess alignment with the Paris Agreement or other international environmental agreements.

The ratings do not explicitly assess alignment with international social or governance agreements. While some assessed ESG issues may overlap with themes addressed by international agreements, no formal alignment or benchmarking against such agreements is made.

General Methodological Disclosures

The Municipal Debt ESG rating attributes each relevant municipal issuer with a score ranging from low to high, with the lowest (1) being best-in-class and the highest (5) being worst-in-class within their industry. The scores are expressed across a normalised distribution within each industry and are intended to reflect ESG risks over a short- to medium-term investment horizon.

An internal industry classification relevant to the fixed income asset class is used.

The methodology draws on a combination of data from external data vendors, such as ICE, and internal datasets, such as proprietary compiled governance data. Because of the nature of the asset class, the data typically does not include CSRD-mandated sustainability statements and SFDR disclosures, as these are primarily intended for corporate issuers. Data inputs are reviewed for relevance and quality and are combined using internal weightings.

The Municipal ESG Ratings are generally updated quarterly and/or at such other times as determined by Insight Investment. Where data gaps exist, these are highlighted to analysts and may be supplemented or estimated via in-house proprietary company surveys, qualitative assessments, or insights gained via engagement with individual municipal issuers.

The methodology is not explicitly derived from academic research nor subject to scientific validation.

Insight Investment does not rely on autonomous artificial intelligence (“AI”) systems for ESG rating creation or maintenance; automated tools may be used to support data collection, processing and/or aggregation, but are subject to appropriate human oversight and governance controls. Nevertheless, there can be no assurance or guarantee that such tools will perform as designed or as intended. If the models or data utilised by such tools are incorrect or incomplete, any decisions made in reliance thereon may lead to inaccurate ratings. The use of such tools has inherent risks. For example, such tools may incorrectly forecast future behaviour, leading to inaccurate ratings. Lastly, the regulatory landscape for AI, data privacy and algorithmic processing is developing rapidly across jurisdictions.  New or amended rules could impose additional controls or constrain certain techniques.  Compliance adaptations may be implemented without notice and may affect related processes, timing or outcomes.

Limitations in data sources, methodologies and information

The ratings are subject to limitations arising from ESG data availability, quality and comparability. Due to the nature of municipal issuers, data typically does not include CSRD or SFDR disclosures and may rely on external providers and internal estimates. The methodology is designed to complement the investment process by providing a best-in-class rating framework and is therefore not suitable for cross-sector comparability or best-in-universe assessments.

There are limitations in the availability of ESG information for municipal issuers, including gaps in disclosures and reliance on third-party data sources. Where data is unavailable, it may be supplemented or estimated through internal analysis, which may affect completeness.

Organisational Disclosures

IIMEL is a wholly owned subsidiary of Insight Investment Management Limited, the ultimate holding company of which is The Bank of New York Mellon Corporation, a corporation registered in the State of Delaware, USA.

The ESG ratings are not sold on a standalone issuer-paid basis. Insight Investment is not remunerated by its investors specifically for the provision of ESG ratings. Fees charged to clients relate to broader investment management and related services rather than ESG ratings. Issuers cannot and do not pay for rating outcomes.

IMEL has established and maintains an effective conflict of interest policy which incorporates procedures seeking to identify, prevent, manage and monitor any conflicts of interest in relation to Insight ESG ratings. There may be potential conflicts of interest that Insight ESG ratings may be influenced through the use of supplementary data inputs and/or manual adjustments, resulting in a rating that differs from the standard model output. Such risks are sought to be mitigated through the application of consistent quantitative methodologies, oversight, appropriate approval of any overrides and monitoring. The above disclosures are illustrative only and do not purport to be a complete enumeration or explanation of all of the conflicts of interest that may be involved in relation to Insight ESG ratings.

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Disclosures

Rating Product Disclosures

The objective of the Securitised Credit ESG Ratings is to identify and assess financially material environmental, social and governance risks linked to specific transactions. The ratings are designed to support investment decision making and engagement by highlighting ESG risks that may affect creditworthiness and short- to medium-term financial performance. The rating assesses ESG risks only; impact on society or the environment is not explicitly assessed.

The methodology covers Environmental, Social and Governance pillars at an individual transaction level. Seven sub-asset classes are explicitly covered: Auto Loan Asset-Backed Securities, Commercial Mortgage-Backed Securities (CMBS), Credit Card ABS, Residential Mortgage-Backed Securities (RMBS), Small and Medium Enterprise (SME) ABS, Whole Business Securitisations (WBS), and Insurance ABS. Transition risk is in scope where financially material and where data availability permits.

There is no single fixed weighting between the E, S and G pillars across all sub-asset classes. Pillar-level weighting is the sum of relevant key issue weights for each asset class and varies materially by collateral type and financially material ESG factors. For example, environmental factors may carry higher weight in Auto Loan ABS and RMBS, while social factors may carry higher weight in Credit Card ABS.

The topics covered are:

• Environmental: Carbon financing and exposure, pollution and waste, and business ethics
• Social: Health and demographic risk, customer relations, and privacy and data security
• Governance: Governance controversies, business ethics, governance controversy, responsible investment trends, and financial system stability

The topics broadly correspond to environmental, social and governance areas but reflect a subset focused on financially material drivers of securitised credit performance. Securitisation SPVs are not subject to CSRD/ESRS reporting, and data is sourced from originator or sponsor disclosures where available.

The ratings are expressed on a scale basis (1–5) and on a relative basis within securitised credit. Comparability across asset classes should be treated with caution due to differing indicator sets and weightings.

The methodology does not explicitly benchmark transactions against the Paris Agreement. Net zero commitment indicators provide an indirect proxy for transition alignment but do not constitute formal alignment.

The methodology does not explicitly benchmark against international social or governance agreements. While certain indicators may overlap with such frameworks, no formal alignment or benchmark is applied.

General Methodological Disclosures

The methodology combines a structured, indicator-based questionnaire with a sub-asset class-specific weighting framework. It is primarily backward-looking and disclosure-based, incorporating forward-looking elements where available. The time horizon is medium-term, aligned with the duration and credit risk analysis of securitised credit transactions. The methodology is not generally based on scientific evidence. Scores are updated upon receipt of material information and/or on a periodic basis.

Sub-asset class classifications are defined internally

Data is sourced from transaction documentation, public disclosures by originators and sponsors, and direct engagement through questionnaires. In some cases, third-party climate risk data is included where data permits. Data sources may include CSRD sustainability statements and SFDR disclosures where available.

Data inputs are reviewed for relevance and quality and combined using internal weightings. Ratings are assigned at the initial investment stage and typically updated every 18 months. Where data gaps exist due to limited disclosure, a conservative (higher) score is applied by default, unless overridden by analysts with documented rationale.

The methodology is not explicitly derived from academic research nor generally based on scientific evidence.

Insight Investment does not rely on autonomous artificial intelligence (“AI”) systems for ESG rating creation or maintenance; automated tools may be used to support data collection, processing and/or aggregation, but are subject to appropriate human oversight and governance controls. Nevertheless, there can be no assurance or guarantee that such tools will perform as designed or as intended. If the models or data utilised by such tools are incorrect or incomplete, any decisions made in reliance thereon may lead to inaccurate ratings. The use of such tools has inherent risks. For example, such tools may incorrectly forecast future behaviour, leading to inaccurate ratings. Lastly, the regulatory landscape for AI, data privacy and algorithmic processing is developing rapidly across jurisdictions.  New or amended rules could impose additional controls or constrain certain techniques.  Compliance adaptations may be implemented without notice and may affect related processes, timing or outcomes.

Limitations in data sources, methodologies and information

The methodology relies on disclosure-based information from originators, sponsors and transaction documentation. Where disclosures are limited, conservative assumptions may be applied. Differences in data availability across transactions and sub-asset classes may affect comparability.

There are limitations in the availability of ESG information, particularly due to reliance on originator disclosures and transaction-level data. Where data is unavailable, estimates or conservative scoring may be applied, which may impact completeness and accuracy.

Organisational Disclosures

IIMEL is a wholly owned subsidiary of Insight Investment Management Limited, the ultimate holding company of which is The Bank of New York Mellon Corporation.

The ESG ratings are not sold on a standalone issuer-paid basis. Insight Investment is not remunerated specifically for ESG ratings. Fees relate to broader investment management and related services. Issuers do not pay for rating outcomes.

IMEL has established and maintains an effective conflict of interest policy which incorporates procedures seeking to identify, prevent, manage and monitor any conflicts of interest in relation to Insight ESG ratings. There may be potential conflicts of interest that Insight ESG ratings may be influenced through the use of supplementary data inputs and/or manual adjustments, resulting in a rating that differs from the standard model output. Such risks are sought to be mitigated through the application of consistent quantitative methodologies, oversight, appropriate approval of any overrides and monitoring. The above disclosures are illustrative only and do not purport to be a complete enumeration or explanation of all of the conflicts of interest that may be involved in relation to Insight ESG ratings.

Category

Disclosures

Rating Product Disclosures

The objective of the Corporate Climate Risk Ratings is to identify and assess financially material climate-related risks faced by corporate issuers. The ratings are designed to support investment decision-making by highlighting how climate risks, including physical and transition risks, may affect creditworthiness and short- to medium-term financial performance. The rating assesses climate-related risks only; corporate impact on climate, including physical and transition impacts, is not explicitly assessed.

The ratings cover exposure to and management of climate-related risks through two pillars: physical risk and transition risk. Scores are produced for individual climate risk issues and aggregated into separate pillar scores. The overall climate risk rating reflects the worst of the physical and transition risk ratings.

Separate physical risk and transition risk pillar scores are calculated. The overall climate risk rating is determined as the worst of the two pillars.

Within the physical pillar, the worst score across acute and chronic risk factors determines the pillar output. The transition pillar reflects emissions profile and reporting, transition leadership, emission target setting, and considerations around products, services and the value chain.

The topics covered are:

• Physical risk: Exposure to acute and chronic climate hazards (e.g. extreme weather such as fire, flood and heatwaves, and long-term shifts such as coastal flooding and water stress)
• Transition risk: Exposure to and strength of leadership integration, targets, emissions and reporting associated with the transition to a low-carbon economy

The topics broadly correspond to the Task Force on Climate-Related Financial Disclosures (TCFD) framework and reflect climate-related risk drivers rather than broader ESG factors.

The ratings are expressed on a relative basis, assessing a company’s climate risk profile in comparison with the relevant universe rather than as an absolute sustainability score.

The ratings do not explicitly measure alignment with international agreements such as the Paris Agreement.

The ratings do not explicitly assess alignment with international social or governance agreements. However, they are conceptually informed by widely recognised frameworks, such as TCFD, which distinguish between physical and transition climate risks and encourage climate risk disclosure and management.

General Methodological Disclosures

Insight Prime is a collection of risk- and outcome-centric frameworks built on financial materiality, sustainability analysis and professional judgement.

The ratings use a structured analytical approach combining multiple third-party ESG data inputs with internal weighting methodologies, including analyst assessments. The methodology focuses on indicators of physical and transition risk based on asset location data, disclosed policies and ambition, while incorporating forward-looking elements where available, such as risk management, target setting and mitigation efforts.

The ratings are intended to reflect climate risk associated with a company across a short- to long-term investment horizon, particularly in the context of credit risk analysis. The methodology is not explicitly derived from academic research nor subject to scientific validation

No specific industry classification is used.

The methodology draws on a combination of external climate data providers, scenario-based modelling inputs, and internal proprietary datasets and analyst insights. Data inputs include information on emissions, sector exposure, geographical asset locations, and climate hazard models.

The Climate Risk Ratings are generally updated quarterly and/or at such other times as determined by Insight Investment. Where data gaps exist, these are highlighted to analysts and may be supplemented or estimated via proprietary company surveys, qualitative assessments or engagement with companies.

The methodology is not explicitly derived from academic research nor subject to scientific validation.

Insight Investment does not rely on autonomous artificial intelligence (“AI”) systems for ESG rating creation or maintenance; automated tools may be used to support data collection, processing and/or aggregation, but are subject to appropriate human oversight and governance controls. Nevertheless, there can be no assurance or guarantee that such tools will perform as designed or as intended. If the models or data utilised by such tools are incorrect or incomplete, any decisions made in reliance thereon may lead to inaccurate ratings. The use of such tools has inherent risks. For example, such tools may incorrectly forecast future behaviour, leading to inaccurate ratings. Lastly, the regulatory landscape for AI, data privacy and algorithmic processing is developing rapidly across jurisdictions.  New or amended rules could impose additional controls or constrain certain techniques.  Compliance adaptations may be implemented without notice and may affect related processes, timing or outcomes.

Limitations in data sources, methodologies and information

The ratings rely partly on modelled data and assumptions, particularly for forward-looking climate scenarios, which introduces uncertainty. The ratings are designed to support risk assessment within an investment context and are not intended as measures of climate impact or temperature alignment.

The ratings are subject to limitations arising from data availability, quality and comparability across issuers and markets. The use of third-party data, modelled inputs and incomplete disclosures may affect completeness and accuracy.

Organisational Disclosures

IIMEL is a wholly owned subsidiary of Insight Investment Management Limited, the ultimate holding company of which is The Bank of New York Mellon Corporation.

The ESG ratings are not sold on a standalone issuer-paid basis. Insight Investment is not remunerated by its investors specifically for the provision of ESG ratings. Fees charged to clients relate to broader investment management and related services rather than ESG ratings. Issuers do not pay for rating outcomes.

IMEL has established and maintains an effective conflict of interest policy which incorporates procedures seeking to identify, prevent, manage and monitor any conflicts of interest in relation to Insight ESG ratings. There may be potential conflicts of interest that Insight ESG ratings may be influenced through the use of supplementary data inputs and/or manual adjustments, resulting in a rating that differs from the standard model output. Such risks are sought to be mitigated through the application of consistent quantitative methodologies, oversight, appropriate approval of any overrides and monitoring. The above disclosures are illustrative only and do not purport to be a complete enumeration or explanation of all of the conflicts of interest that may be involved in relation to Insight ESG ratings.

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Disclosures

Rating Product Disclosures

The objective of the Sovereign Climate Physical Risk Rating is to rank countries based on their exposure and sensitivity to physical climate risks. The ratings are designed to support investment decision-making and engagement by highlighting physical risks that may affect creditworthiness and short- to medium-term financial performance. The rating assesses physical climate risks only; sovereign impact on society or the environment is not explicitly assessed.

The model covers sovereign issuers across developed and emerging markets, assessing exposure to both acute risks (e.g. floods, storms and heatwaves) and chronic risks (e.g. sea level rise and changing precipitation patterns). It focuses exclusively on physical climate risks and excludes transition risk and broader macro-financial factors such as fiscal strength.

The model is constructed around three components:

• Long-term vulnerability (ND-GAIN exposure and sensitivity) – 60% weight
• Short-term physical risk impacts (NGFS scenarios) – 60% weight
• Adaptive capacity and readiness (ND-GAIN readiness) – 20% offset

The negative weighting for adaptive capacity reflects that stronger readiness reduces overall risk exposure.

The topics covered include:

• Short-term physical climate risks (2025–2030), based on NGFS scenario modelling of extreme weather impacts and their effects on productivity, output and capital destruction
• Long-term vulnerability and readiness, based on the ND-GAIN Index

The ratings are informed indirectly by scientific research through the use of NGFS scenarios and ND-GAIN data, which are grounded in established climate science frameworks.

The ratings are expressed on a relative basis, assessing a sovereign issuer’s climate risk exposure and management compared with its peers. Ratings are expressed on a 1–5 scale, where 1 represents lower risk and 5 represents higher risk.

The ratings do not explicitly measure alignment with the Paris Agreement or other international environmental agreements.

The ratings do not explicitly assess alignment with international social or governance agreements, although they are indirectly informed by internationally recognised frameworks such as NGFS scenarios and the ND-GAIN Index.

General Methodological Disclosures

The ratings use a structured analytical approach combining multiple third-party data inputs with internal weighting methodologies, including analyst assessments. The methodology combines short-term and long-term physical climate risk assessments into a composite score designed to capture both exposure and adaptive capacity.

No specific industry classification is applied; the model covers sovereign issuers.

The methodology draws on NGFS short-term climate scenarios and the ND-GAIN Index. These datasets provide forward-looking scenario analysis and structural vulnerability assessment. Data inputs are reviewed and combined using internal weighting methodologies.

The ratings are informed indirectly by scientific research through their reliance on NGFS scenarios and ND-GAIN data; however, the methodology itself is not explicitly derived from academic research.

Insight Investment does not rely on autonomous artificial intelligence (“AI”) systems for ESG rating creation or maintenance; automated tools may be used to support data collection, processing and/or aggregation, but are subject to appropriate human oversight and governance controls. Nevertheless, there can be no assurance or guarantee that such tools will perform as designed or as intended. If the models or data utilised by such tools are incorrect or incomplete, any decisions made in reliance thereon may lead to inaccurate ratings. The use of such tools has inherent risks. For example, such tools may incorrectly forecast future behaviour, leading to inaccurate ratings. Lastly, the regulatory landscape for AI, data privacy and algorithmic processing is developing rapidly across jurisdictions.  New or amended rules could impose additional controls or constrain certain techniques.  Compliance adaptations may be implemented without notice and may affect related processes, timing or outcomes.

Limitations in data sources, methodologies and information

The model is subject to limitations arising from evolving and incomplete short-term scenario coverage across countries. Results depend on NGFS scenario assumptions and modelled impacts. While adaptive capacity is incorporated, broader macroeconomic resilience factors are not fully captured.

The ratings rely on external datasets and modelled inputs, which may be incomplete or subject to assumptions. Limitations in country-level data availability and consistency may impact the completeness and accuracy of the ratings.

Organisational Disclosures

IIMEL is a wholly owned subsidiary of Insight Investment Management Limited, the ultimate holding company of which is The Bank of New York Mellon Corporation, a corporation registered in the State of Delaware, USA.

The ESG ratings are not sold on a standalone issuer-paid basis. Insight Investment is not remunerated by its investors specifically for the provision of ESG ratings. Fees charged to clients relate to broader investment management and related services rather than the provision of ESG ratings. Issuers cannot and do not pay for rating outcomes.

IMEL has established and maintains an effective conflict of interest policy which incorporates procedures seeking to identify, prevent, manage and monitor any conflicts of interest in relation to Insight ESG ratings. There may be potential conflicts of interest that Insight ESG ratings may be influenced through the use of supplementary data inputs and/or manual adjustments, resulting in a rating that differs from the standard model output. Such risks are sought to be mitigated through the application of consistent quantitative methodologies, oversight, appropriate approval of any overrides and monitoring. The above disclosures are illustrative only and do not purport to be a complete enumeration or explanation of all of the conflicts of interest that may be involved in relation to Insight ESG ratings.

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Disclosures

Rating Product Disclosures

The objective of the Corporate Net Zero Maturity Ratings is to provide a singular, quantitative assessment of a corporate issuer’s alignment with, or pathway towards, net zero emissions.

The ratings are designed to support investment decision making and engagement by highlighting a company’s alignment with net zero. The rating is not designed to assess ESG risks and is not intended to capture potential impacts on creditworthiness or short- to medium-term financial performance. Instead, it reflects future corporate impact on society or the environment

The ratings cover net zero alignment factors rather than environmental, social and governance risks. They assess alignment with net zero maturity classifications: Not Aligned → Committed → Aligning → Aligned → Achieving. The scope therefore focuses on transition-related climate alignment rather than broader ESG factors.

The model is non-weighted and rules-based. An issuer can meet the maturity requirements through multiple data points. Ratings depend on whether issuers meet a minimum set of criteria thresholds, which vary depending on their materiality classification (high impact, material or less material sectors). No fixed weighting is applied.

The topics covered include key net zero alignment factors, including ambition, target setting, emissions performance, disclosure, decarbonisation strategy, capital allocation alignment and climate policy engagement.

The criteria vary depending on sector materiality, with more stringent requirements applied to high-impact sectors.

The framework is derived from the IIGCC Paris Aligned Investment Initiative (PAII) and reflects a subset of topics focused on net zero alignment rather than the full set of ESRS sustainability reporting topics.

The ratings are expressed as categorical maturity stages rather than absolute or relative scores:

• Not Aligned
• Committed
• Aligning
• Aligned
• Achieving

The classification reflects whether an issuer meets the required criteria for its sector materiality level.

The framework is explicitly grounded in the IIGCC Paris Aligned Investment Initiative (PAII), which aims to align portfolios with net zero emissions by 2050.

No explicit assessment of alignment with international social or governance agreements is included.

General Methodological Disclosures

The ratings use a structured analytical approach combining multiple third-party data inputs with internal, hurdle-based methodologies, including analyst assessments. The methodology focuses primarily on forward-looking indicators of net zero alignment, including policies, target setting, decarbonisation strategy, capital allocation and governance.

The approach is rules-based, assessing whether issuers meet defined criteria thresholds. The methodology is not explicitly derived from academic research nor subject to scientific validation.

The industry classification is aligned with the PAII framework, categorising companies into high-impact, material and less material sectors.

The methodology integrates multiple external and internal datasets, including MSCI, Climate Action 100+ Benchmark, the Transition Pathway Initiative (TPI) and the Science Based Targets Initiative.

Vendor scores are not used directly; instead, raw data points are used to assess alignment against framework requirements. These inputs are reviewed and applied within the rules-based framework.

The methodology is derived from industry frameworks, in particular the IIGCC Paris Aligned Investment Initiative, and is not explicitly based on academic scientific evidence.

Insight Investment does not rely on autonomous artificial intelligence (“AI”) systems for ESG rating creation or maintenance; automated tools may be used to support data collection, processing and/or aggregation, but are subject to appropriate human oversight and governance controls. Nevertheless, there can be no assurance or guarantee that such tools will perform as designed or as intended. If the models or data utilised by such tools are incorrect or incomplete, any decisions made in reliance thereon may lead to inaccurate ratings. The use of such tools has inherent risks. For example, such tools may incorrectly forecast future behaviour, leading to inaccurate ratings. Lastly, the regulatory landscape for AI, data privacy and algorithmic processing is developing rapidly across jurisdictions.  New or amended rules could impose additional controls or constrain certain techniques.  Compliance adaptations may be implemented without notice and may affect related processes, timing or outcomes.

Limitations in data sources, methodologies and information

The methodology is a framework-based assessment rather than a financial risk model. It is rules-based and binary at the question level, which may limit nuance. It relies on disclosure and external datasets, which may be incomplete or inconsistent. Outputs are dependent on materiality classification assumptions.

There are limitations in the availability and consistency of data used, including reliance on external datasets and issuer disclosures. Data gaps or inconsistencies may affect completeness and accuracy.

Organisational Disclosures

IIMEL is a wholly owned subsidiary of Insight Investment Management Limited, the ultimate holding company of which is The Bank of New York Mellon Corporation, a corporation registered in the State of Delaware, USA.

The ESG ratings are not sold on a standalone issuer-paid basis. Insight Investment is not remunerated by its investors specifically for the provision of ESG ratings. Fees relate to broader investment management and related services rather than ESG ratings. Issuers cannot and do not pay for rating outcomes.

The ESG rating activities operate under defined governance arrangements, including oversight of methodologies, controls around rating adjustments and documentation of material judgements, with separation between ESG rating activities and portfolio management decision making.

IMEL has established and maintains an effective conflict of interest policy which incorporates procedures seeking to identify, prevent, manage and monitor any conflicts of interest in relation to Insight ESG ratings. There may be potential conflicts of interest that Insight ESG ratings may be influenced through the use of supplementary data inputs and/or manual adjustments, resulting in a rating that differs from the standard model output. Such risks are sought to be mitigated through the application of consistent quantitative methodologies, oversight, appropriate approval of any overrides and monitoring. The above disclosures are illustrative only and do not purport to be a complete enumeration or explanation of all of the conflicts of interest that may be involved in relation to Insight ESG ratings.

Category

Disclosures

Rating Product Disclosures

The objective of the Sovereign Net Zero Maturity Ratings is to provide a singular, quantitative assessment of a sovereign issuer’s alignment with, or pathway towards, net zero emissions.

The ratings are designed to support investment decision making and engagement by highlighting a country’s alignment with net zero. The rating is not intended to assess ESG risks and is not intended to capture potential impacts on creditworthiness or short- to medium-term financial performance. Instead, it reflects future sovereign impact on society or the environment.

The ratings cover sovereign issuers and their alignment with net zero. The scope excludes labelled bonds, sub-sovereigns and supranationals. The ratings focus on net zero alignment factors rather than environmental, social and governance risk.

The model is non-weighted and rules-based. An issuer can meet the maturity requirements through multiple data points. Ratings depend on whether issuers meet a minimum set of criteria thresholds, which vary depending on their country classification. Country classification (developed versus emerging) sets different requirements, with more stringent criteria applied to developed economies.

The topics covered include net zero alignment factors such as ambition, net zero targets, emissions disclosure, decarbonisation strategy, emissions performance and budget alignment.

The framework classifies countries by CBDR+RC categories (Developed Economies and Developing and Emerging Economies) and applies differentiated criteria accordingly.

The framework is derived from the IIGCC Paris Aligned Investment Initiative and reflects a subset of topics focused on net zero alignment rather than the full ESRS sustainability reporting framework.

The ratings are expressed as categorical maturity stages:

• Not Aligned
• Committed
• Aligning
• Aligned
• Achieving

The classification reflects whether a sovereign issuer meets the required criteria for its country classification level, rather than a relative ranking across the full universe.

The framework is explicitly grounded in the Paris Agreement and the IIGCC Net Zero Investment Framework, incorporating Paris-aligned targets, Nationally Determined Contributions (NDCs) and climate finance commitments.

No explicit assessment is made against international social or governance agreements beyond those embedded within the Paris Agreement framework and related global commitments.

General Methodological Disclosures

The ratings use a structured analytical approach combining multiple third-party data inputs with internal, hurdle-based methodologies, including analyst assessments. The methodology focuses on forward-looking indicators of net zero alignment, including ambition, targets, emissions disclosure, decarbonisation strategy, emissions performance and budget alignment.

The approach is rules-based and assesses whether issuers meet defined criteria thresholds.

The classification framework distinguishes between Developed Economies and Developing and Emerging Economies, in line with CBDR+RC principles.

The methodology integrates multiple external and internal datasets, including ASCOR, MSCI, REN21, World Bank and IMF data. Vendor scores are not used directly; instead, raw data points are used to assess alignment with the framework requirements.

The framework is derived from industry and policy frameworks, including the Paris Agreement and IIGCC Net Zero Investment Framework, and is not explicitly derived from academic scientific research.

Insight Investment does not rely on autonomous artificial intelligence (“AI”) systems for ESG rating creation or maintenance; automated tools may be used to support data collection, processing and/or aggregation, but are subject to appropriate human oversight and governance controls. Nevertheless, there can be no assurance or guarantee that such tools will perform as designed or as intended. If the models or data utilised by such tools are incorrect or incomplete, any decisions made in reliance thereon may lead to inaccurate ratings. The use of such tools has inherent risks. For example, such tools may incorrectly forecast future behaviour, leading to inaccurate ratings. Lastly, the regulatory landscape for AI, data privacy and algorithmic processing is developing rapidly across jurisdictions.  New or amended rules could impose additional controls or constrain certain techniques.  Compliance adaptations may be implemented without notice and may affect related processes, timing or outcomes.

Limitations in data sources, methodologies and information

The methodology is a framework-based assessment rather than a financial risk model. It is rules-based and binary at the question level, which may limit nuance. It relies on disclosure and external datasets, which may be incomplete or inconsistent. Outputs depend on country classification assumptions.

There are limitations in the availability and consistency of data used, including reliance on external datasets and sovereign disclosures. Data gaps or inconsistencies may affect completeness and accuracy.

Organisational Disclosures

IIMEL is a wholly owned subsidiary of Insight Investment Management Limited, the ultimate holding company of which is The Bank of New York Mellon Corporation, a corporation registered in the State of Delaware, USA.

The ESG ratings are not sold on a standalone issuer-paid basis. Insight Investment is not remunerated by its investors specifically for the provision of ESG ratings. Fees charged to clients relate to broader investment management and related services rather than ESG ratings. Issuers cannot and do not pay for rating outcomes.

IMEL has established and maintains an effective conflict of interest policy which incorporates procedures seeking to identify, prevent, manage and monitor any conflicts of interest in relation to Insight ESG ratings. There may be potential conflicts of interest that Insight ESG ratings may be influenced through the use of supplementary data inputs and/or manual adjustments, resulting in a rating that differs from the standard model output. Such risks are sought to be mitigated through the application of consistent quantitative methodologies, oversight, appropriate approval of any overrides and monitoring. The above disclosures are illustrative only and do not purport to be a complete enumeration or explanation of all of the conflicts of interest that may be involved in relation to Insight ESG ratings.

Category

Disclosures

Rating Product Disclosures

The objective of the Impact Issuer Rating is to assess whether a significant part of an issuer’s business derives positive environmental and/or social impact, defined through revenue alignment with the UN Sustainable Development Goals (SDGs) or the EU Taxonomy, while minimising adverse impacts on any other SDG through appropriate mitigation measures.

The rating is designed to assess impact, rather than financial risk, and is not intended to capture potential impacts on creditworthiness or short- to medium-term financial performance.

The rating covers environmental and social impact dimensions through the assessment of positive impact and adverse impact. The scope is not an aggregated E, S and G risk rating but rather an impact-focused assessment based on alignment with SDGs and the EU Taxonomy.

The methodology is threshold-based and does not apply specific weightings. Issuers must meet defined criteria for both positive impact and adverse impact mitigation to be classified as an impact issuer.

The topics covered include:

• Positive environmental and/or social impact through revenue alignment with the UN SDGs and/or EU Taxonomy
• Avoidance and mitigation of adverse impacts, including exclusions, “do no significant harm” (DNSH) considerations, global norms compliance and absence of severe ESG controversies

These topics are aligned with internationally recognised frameworks, including the UN SDGs and EU Taxonomy.

The rating is expressed on a binary basis: an issuer is classified as either an impact issuer or not (pass/fail).

No specific assessment of alignment with the Paris Agreement is included. However, environmental impact alignment may be reflected through EU Taxonomy-aligned activities.

The methodology is aligned with international frameworks, including the UN Sustainable Development Goals and global norms.

General Methodological Disclosures

The methodology assesses two key areas: positive impact and adverse impact.

Positive impact requires:

• At least 50% of revenue aligned to the UN SDGs and/or EU Taxonomy; or
• At least 20% of revenue aligned, with at least 50% of capital expenditure linked to positive environmental and/or social impact or EU Taxonomy-aligned activities; and
• A qualitative assessment confirming measurable positive impact.

Adverse impact is assessed through exclusions, DNSH flags, global norms compliance, the absence of severe ESG controversies and the identification and mitigation of potential adverse impacts.

No specific industry classification is applied.

The methodology uses both external and internal data sources. External sources include MSCI Sustainable Impact Solutions, UNEP BICS SDG Sector Mapping and MSCI Controversies. Where external data is unavailable or inaccurate, internal assessments are used to estimate revenue alignment with impactful activities.

The methodology is based on internationally recognised frameworks, including the UN SDGs and EU Taxonomy, and is not explicitly derived from academic scientific research.

Insight Investment does not rely on autonomous artificial intelligence (“AI”) systems for ESG rating creation or maintenance; automated tools may be used to support data collection, processing and/or aggregation, but are subject to appropriate human oversight and governance controls. Nevertheless, there can be no assurance or guarantee that such tools will perform as designed or as intended. If the models or data utilised by such tools are incorrect or incomplete, any decisions made in reliance thereon may lead to inaccurate ratings. The use of such tools has inherent risks. For example, such tools may incorrectly forecast future behaviour, leading to inaccurate ratings. Lastly, the regulatory landscape for AI, data privacy and algorithmic processing is developing rapidly across jurisdictions.  New or amended rules could impose additional controls or constrain certain techniques.  Compliance adaptations may be implemented without notice and may affect related processes, timing or outcomes.

Limitations in data sources, methodologies and information

The methodology is a threshold-based, framework-driven assessment rather than a financial model. It relies on issuer-level assessments and qualitative judgement, which may introduce subjectivity.

The methodology relies on issuer disclosures and external datasets, which may be incomplete, inconsistent or subject to limitations. Data gaps may affect the accuracy of the assessment.

Organisational Disclosures

IIMEL is a wholly owned subsidiary of Insight Investment Management Limited, the ultimate holding company of which is The Bank of New York Mellon Corporation, a corporation registered in the State of Delaware, USA.

The ESG ratings are not sold on a standalone issuer-paid basis. Insight Investment is not remunerated by its investors specifically for the provision of ESG ratings. Fees charged to clients relate to broader investment management and related services rather than ESG ratings. Issuers cannot and do not pay for rating outcomes.

IMEL has established and maintains an effective conflict of interest policy which incorporates procedures seeking to identify, prevent, manage and monitor any conflicts of interest in relation to Insight ESG ratings. There may be potential conflicts of interest that Insight ESG ratings may be influenced through the use of supplementary data inputs and/or manual adjustments, resulting in a rating that differs from the standard model output. Such risks are sought to be mitigated through the application of consistent quantitative methodologies, oversight, appropriate approval of any overrides and monitoring. The above disclosures are illustrative only and do not purport to be a complete enumeration or explanation of all of the conflicts of interest that may be involved in relation to Insight ESG ratings.

Category

Disclosures

Rating Product Disclosures

The objective of the Sustainable Investment Rating for corporates is to determine whether an issuer or instrument can be categorised as a sustainable investment under SFDR Article 2(17). The assessment considers whether the investment contributes to an environmental or social objective, does no significant harm, and meets good governance requirements.

The rating assesses sustainability classification (impact) rather than ESG risks and is not intended to capture potential impacts on creditworthiness or short- to medium-term financial performance.

The rating covers sustainable investment classification across Impact Bonds, Impact Issuers and Sustainably Aligned Issuers. The scope focuses on environmental and social contribution, do no significant harm and good governance criteria rather than a full aggregated E, S and G risk rating.

The methodology is threshold-based and does not apply specific weightings. An investment may qualify as a sustainable investment if it meets one of the defined criteria (Impact Bond, Impact Issuer or Sustainably Aligned Issuer) and satisfies all required thresholds.

The topics covered include:

• Contribution to environmental and/or social objectives (aligned with UN SDGs or EU Taxonomy)
• Do No Significant Harm (DNSH), including Principal Adverse Impact (PAI) indicators and exclusion screening
• Good governance requirements

These criteria align with the requirements of SFDR Article 2(17) and reflect internationally recognised sustainability frameworks.

The rating is expressed as a binary classification indicating whether an investment qualifies as a sustainable investment. For Impact Bonds, eligibility is linked to Light Green or Dark Green classification. For Impact Issuers and Sustainably Aligned Issuers, classification depends on whether revenue and/or capital expenditure thresholds are met.

No explicit assessment of alignment with the Paris Agreement is specified; however, environmental objectives may be aligned with EU Taxonomy-aligned activities.

The methodology incorporates elements aligned with international frameworks, including the UN Sustainable Development Goals and good governance standards.

General Methodological Disclosures

The methodology assesses whether an issuer or instrument qualifies as a sustainable investment by determining if it meets one of three criteria: Impact Bond, Impact Issuer or Sustainably Aligned Issuer.

Sustainably Aligned Issuers are defined as issuers with at least 20% of revenue linked to positive environmental and/or social impacts, using the UN SDGs or EU Taxonomy as guidance.

To qualify as a sustainable investment, an issuer or instrument must:

• Contribute to an environmental or social objective;
• Do no significant harm; and
• Meet good governance requirements.

No specific industry classification is applied.

The assessment uses impact bond ratings, issuer revenue and capital expenditure data, sustainability disclosures, UN SDG alignment, EU Taxonomy information, PAI indicators and exclusion screening.

Data inputs are reviewed to determine whether the relevant criteria are met.

The methodology is based on regulatory and industry frameworks, including SFDR, UN SDGs and the EU Taxonomy, and is not explicitly derived from academic scientific research.

Insight Investment does not rely on autonomous artificial intelligence (“AI”) systems for ESG rating creation or maintenance; automated tools may be used to support data collection, processing and/or aggregation, but are subject to appropriate human oversight and governance controls. Nevertheless, there can be no assurance or guarantee that such tools will perform as designed or as intended. If the models or data utilised by such tools are incorrect or incomplete, any decisions made in reliance thereon may lead to inaccurate ratings. The use of such tools has inherent risks. For example, such tools may incorrectly forecast future behaviour, leading to inaccurate ratings. Lastly, the regulatory landscape for AI, data privacy and algorithmic processing is developing rapidly across jurisdictions.  New or amended rules could impose additional controls or constrain certain techniques.  Compliance adaptations may be implemented without notice and may affect related processes, timing or outcomes.

Limitations in data sources, methodologies and information

The methodology is a threshold-based classification and not a financial or risk model. It depends on the availability of issuer- and instrument-level information and the application of defined criteria.

Classification depends on the availability and quality of issuer and instrument-level information. Where information is incomplete, this may limit the ability to identify a sustainable investment.

Organisational Disclosures

IIMEL is a wholly owned subsidiary of Insight Investment Management Limited, the ultimate holding company of which is The Bank of New York Mellon Corporation, a corporation registered in the State of Delaware, USA.

The ESG ratings are not sold on a standalone issuer-paid basis. Insight Investment is not remunerated by its investors specifically for the provision of ESG ratings. Fees charged to clients relate to broader investment management and related services rather than ESG ratings. Issuers cannot and do not pay for rating outcomes.

IMEL has established and maintains an effective conflict of interest policy which incorporates procedures seeking to identify, prevent, manage and monitor any conflicts of interest in relation to Insight ESG ratings. There may be potential conflicts of interest that Insight ESG ratings may be influenced through the use of supplementary data inputs and/or manual adjustments, resulting in a rating that differs from the standard model output. Such risks are sought to be mitigated through the application of consistent quantitative methodologies, oversight, appropriate approval of any overrides and monitoring. The above disclosures are illustrative only and do not purport to be a complete enumeration or explanation of all of the conflicts of interest that may be involved in relation to Insight ESG ratings.