Notification of Sustainable Investment commitment changes to the underlying funds of various abrdn funds

10 Mar 2026

Notification of changes to the underlying funds of:

(together the “Affected Mirror Funds”)

The Board of Directors of abrdn SICAV I (the “Company”) have notified us of upcoming changes to the underlying funds of the Affected Mirror Funds, which will take effect from 26 March 2026 (the “Effective Date”).

Background

The Company is committed to reviewing its range of funds with the aim of ensuring that they continue to meet client and regulatory requirements and expectations. This includes ongoing monitoring of the overall sustainability framework and the Sustainable Investment commitments within all their funds which are classified as Article 8 under the EU’s Sustainable Finance Disclosure Regulation (“SFDR”).

Updates to the Sustainability Framework - applicable to Affected Mirror Funds 1-4

The Investment Manager of the underlying funds of the Affected Mirror Funds, Aberdeen Investments Limited (“Aberdeen Investments”), has undertaken a review of the overall framework it uses to assess a company’s sustainability and how this applies to the Company’s SFDR Article 8 classified funds. As a result of the review, the currently used ESG House Score will be replaced with a new Overall Sustainability Assessment (“OSA”) from the Effective Date. Rather than setting a fixed percentage of companies to be excluded (as is currently the case under the ESG House Score), the OSA will provide a clearer and more comprehensive sustainability profile of each of its funds based on the attributes and categorisation of the underlying companies. 

The OSA will provide an overall view on a company’s sustainability based on scoring of its governance, operations, and products and/or services. This broader assessment of sustainability will allow Aberdeen Investments to assess and review its funds’ holdings in a more holistic and transparent manner.

These updates will also bring greater consistency to the minimum commitments to investments that are aligned with environmental or social characteristics, broadly set at 80% for “Article 8 Sustainable Funds” (which includes the underlying funds of Affected Mirror Funds 1-2) or 70% for its “Article 8 Promoting ESG Funds” (which includes the underlying funds of Affected Mirror Funds 3-4). 

Updates to the Sustainable Investment methodology - applicable to Affected Mirror Funds 1-4

Best practices in sustainable investment methodologies are still developing across the industry, and Aberdeen Investments has kept its approach under continual review to ensure it remains robust and responds to an evolving regulatory landscape in the EU. As part of this, Aberdeen Investments has updated its Sustainable Investment methodology across all Article 8 SFDR classified funds. 

The current methodology assigns a pro-rata proportion of an investment as sustainable based on its economic contribution. From the Effective Date, the new methodology will look more holistically at the sustainability of a company, considering the combination of governance, operations, and the products and/or services which will allow a more robust and rounded assessment of whether a company is or is not considered sustainable (i.e. 0% or 100%) under the SFDR definition. This assessment utilises the componentry that makes up the OSA.

Increase of minimum Sustainable Investment commitments - applicable to Affected Mirror Funds 1-2

As a result of the update to the sustainable investment methodologies, the minimum Sustainable Investment commitments of Affected Mirror Funds 1-2, will be increased from the Effective Date, as set out below. 

There will be no rebalancing required, and the risk profiles of the underlying funds remain unchanged. No changes to the portfolios are required as the current holdings of the underlying funds of Affected Mirror Funds 1-2 already satisfy the new increased minimum commitments required under the updated methodology.

Discontinuation of ESG rating against benchmark commitment - applicable to Affected Mirror Funds 3-4

From the Effective Date, the underlying funds of Affected Mirror Funds 3-4 will no longer make a commitment in relation to the ESG rating against the benchmark in order to ensure, to the extent possible, greater harmonisation across the framework.

Update in relation to transition opportunities for SFDR Article 8 Funds - applicable to Affected Mirror Fund 3

From the Effective Date, flexibility will be added to the underlying fund of Affected Mirror Fund 3, to permit a limited proportion of the underlying fund to be invested in opportunities which do not pass the Thermal Coal screen where there is sufficient evidence to support the transition pathway that would lead to compliance with the screen.

These changes will take effect automatically and policyholders do not need to take any action. 

Should you have any questions regarding these changes, please contact the Investment Marketing Team.

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*Fund variant applicable to Hong Kong designated policyholders.