A. Summary

The Fund promotes environmental or social characteristics, but does not have as its objective sustainable investment. The Fund does not commit to holding Sustainable Investments, however, they may form part of the portfolio. The Fund seeks to: (i) address key environmental and social issues using ESG scoring; (ii) limit the greenhouse gas emissions intensity of the portfolio; and (iii) apply the BlackRock EMEA Baseline Screens.

The investment objective of the Fund is to provide a return in line with money market rates consistent with preservation of principal and liquidity by the maintenance of a portfolio of High Credit Quality short term “money market” instruments. The binding elements of the investment strategy are as follows: (1) Ensure that more than 90% of the issuers of securities in which the Fund invests shall be ESG rated or have been analysed for ESG purposes. (2) Maintain that at least 80% of the Fund’s assets (which are not investments in government and public securities and instruments) have above average environmental practices as determined by MSCI or such other external ESG research provider used by the Investment Manager from time to time. MSCI rank corporate issuers based on an issuers’ overall MSCI environmental score. Corporate issuers that are ranked by MSCI to be in the first or second quartile for the MSCI environmental score are eligible for investment by the Fund (for example, corporate issuers that have low carbon emissions, sustainable use of natural resources, responsible waste management practices and use of renewable energy).; (3) Maintain that at least 80% of Fund assets (which are not investments in government and public securities and instruments) have above average environmental practices as determined by MSCI or such other external ESG research provider used by the Investment Manager from time to time; (4) Subject always to investing in such assets as required for the Fund to meet its investment objective, the Investment Manager will manage the Fund to promote environmental and social characteristics based on the environmental and social criteria set out below. When selecting the Fund’s investments, the Investment Manager will, as a non-financial objective, exclude direct investment in issuers of money market instruments which, at the time of investment: i) derive 5% or more of their revenues from fossil fuel mining, exploration and/or refinement; ii) have a MSCI ESG rating of CCC; iii) have a MSCI Controversy Score of ‘0’; iv) have, in the case of any Supranational and Agency Entities, an MSCI ESG rating of B or below; or v) are caught by the BlackRock EMEA Baseline Screens (as described below and in Appendix III); (5) BlackRock EMEA Baseline Screens: The Investment Manager will seek to limit and/or exclude direct investment (as applicable) in corporate issuers which, at the time of purchase, in the opinion of the Investment Manager, have been deemed to have failed to comply with UN Global Compact Principles or have exposure to, or ties with, certain sectors (in some cases subject to specific revenue thresholds): i) the production of certain types of controversial weapons; ii) the distribution or production of firearms or small arms ammunition intended for retail to civilians; iii) the extraction of certain types of fossil fuel and/or the generation of power from them; or iv) the production of tobacco products or certain activities in relation to tobacco-related products; (6) A full list of the BlackRock EMEA Baseline Screens limits and/or exclusions being applied by Investment Managers at any time (including any specific threshold criteria) is available at https://www.blackrock.com/corporate/ literature/publication/blackrock-baselinescreens-in-europe-middleeast-and-africa.pdf. The Fund considers PAIs on sustainability factors through the application of its carbon reduction target and its exclusionary policy.

A minimum of 80% of the Fund's total assets will be invested in investments that are aligned with the environmental and/or social characteristics. The Fund may invest up to 20% of its total assets in other investments. The Fund does not currently commit to invest more than 0% of its assets in Sustainable Investments with an environmental objective aligned with the EU Taxonomy, however, these investments may form part of the portfolio.  

The Fund does not currently commit to invest in fossil gas and/or nuclear energy related activities that comply with the EU Taxonomy, however, these investments may form part of the portfolio.

BlackRock has developed a highly automated compliance process to help ensure that the Fund is managed in accordance with its stated investment guidelines and applicable regulatory requirements. This includes monitoring of the environmental or social characteristics of the Fund in accordance with the relevant methodology.BlackRock uses a number of methodologies to measure how the social or environmental characteristics promoted by the Fund are met.

BlackRock Portfolio Managers have access to research, data, tools, and analytics to integrate ESG insights into their investment process. ESG datasets are sourced from external third-party data providers, including but not limited to MSCI, Sustainalytics, Refinitiv, S&P and Clarity AI. BlackRock applies a comprehensive due diligence process to evaluate provider offerings with highly targeted methodology reviews and coverage assessments based on the sustainable investment strategy of the product. Data, including ESG data, received through our existing interfaces, and then processed through a series of quality control and completeness checks which seeks to ensure that data is high-quality data before being made available for use downstream within BlackRock systems and applications, such as Aladdin. BlackRock strives to capture as much reported data from companies via 3rd party data providers as practicable, however, industry standards around disclosure frameworks are still evolving, particularly with respect to forward looking indicators. As a result, in certain cases we rely on estimated or proxy measures from data providers to cover our broad investible universe of issuers.

BlackRock continues to monitor developments in the EU's ongoing implementation of its framework for sustainable investing and its investment methodologies seeking to ensure alignment as the regulatory environment changes. ESG data sets are constantly changing and improving as disclosure standards, regulatory frameworks and industry practice evolve. BlackRock continues to work with a broad range of market participants to improve data quality. Sustainable investing and understanding of sustainability is also evolving along with the data environment. Industry participants face challenges in identifying a single metric or set of standardized metrics to provide a complete view on a company or an investment. BlackRock has therefore established a framework to identify sustainable investments.

BlackRock applies a high standard of due diligence in the selection and ongoing monitoring of investments made by the Fund for the purpose of compliance with the investment, liquidity and risk guidelines of the Fund, as well as the sustainability risk and ESG criteria and general performance.

Engagement with companies in which we invest our clients’ assets occurs at multiple levels within BlackRock. Where investment teams chooses to leverage engagement, this can take a variety of forms but, in essence, the portfolio management team would seek to have regular and continuing dialogue with executives or board directors of engaged investee companies to advance sound governance and sustainable business practices targeted at the identified ESG characteristics and principal adverse indicators, as well as to understand the effectiveness of the company’s management and oversight of activities designed to address the identified ESG issues. Engagement also allows the portfolio management team to provide feedback on company practices and disclosures.

There is no specific index designated as a reference benchmark to determine whether this Fund is aligned with the environmental and/or social characteristics that it promotes.

B. No sustainable investment objective

This financial product promotes environmental or social characteristics, but does not have as its objective sustainable investment.

The Fund does not commit to investing in Sustainable Investments, however, they may form part of the portfolio. Please refer to 'Section D - Investment Strategy', which describes how the Fund considers PAI on sustainability factors.

C. Environmental or social characteristics of the financial product

The Fund promotes environmental characteristics related to the reduction of use of non-sustainable energy sources by excluding issuers who derive 5% or more of their revenues from fossil fuel mining, exploration and/or refinement.

The Fund promotes environmental characteristics related to the reduction of environmental related controversies by excluding issuers which have a ‘red’ MSCI ESG controversy flag, in relation to an issuer’s involvement (or alleged involvement) in very severe controversies, relating to, for example, biodiversity and land use, energy and climate change, water stress, toxic emissions and waste issues. Additionally, the Fund excludes issuers who have a MSCI ESG rating of CCC and exclude any Supranational and Agency Entities that have an MSCI ESG rating of B or below. An MSCI ESG controversy score measures an issuer’s involvement (or alleged involvement) in controversies based on the ESG data provider’s assessment of an issuer’s operations, products and/or services which are deemed to have a negative ESG impact. MSCI assigns an ESG controversy score depending on the severity of a company’s involvement in a controversy, whether the involvement is direct or indirect and whether the controversy is ongoing, partially concluded or concluded. A ’red’ MSCI ESG controversy flag denotes a company’s direct involvement in a very severe ongoing controversy. In addition to the ‘red’ MSCI flag, ‘orange’, ‘yellow’ and ‘green’ flags are used to denote a company’s involvement in ESG controversies. A ’red’ flag denotes the most severe ESG controversy, followed by ’orange’, then ’yellow’ with a ’green’ flag denoting the least severe controversy.

The Fund promotes environmental characteristics related to the reduction of carbon emissions by seeking to have a lower greenhouse gas emission intensity (for Scope 1 and 2 as explained below) within its portfolio relative to the Investment Universe. Greenhouse gas emissions are categorised into three groups or “scopes” by the most widely-used international accounting tool, the Greenhouse Gas (GHG) Protocol. Scope 1 covers direct emissions from owned or controlled sources. Scope 2 covers indirect emissions from the generation of purchased electricity, steam, heating and cooling consumed by the reporting issuer. Scope 3 includes all other indirect emissions that occur in an issuer’s value chain but Scope 3 is not covered in the reduction. The estimated greenhouse gas (Scope 1 and Scope 2) emissions per $1 million of sales revenue across the Fund’s holdings are used to measure this aim.

Additionally, the Fund promotes environmental characteristics related to reduction of environmental pollution by excluding direct investment in companies that are involved in thermal coal and tar and sands extraction, as well as thermal coal-based power generation, through application of the BlackRock EMEA Baseline Screens.

The Fund promotes social characteristics related to (a) reduction of the availability of weapons by excluding direct investment in issuers involved in the production of controversial weapons and nuclear weapons, and production and distribution of civilian firearms, (b) better health and wellbeing by excluding direct investment in issuers involved in production and distribution of tobacco; and (c) support for human rights, labour standards, the environment and anti-corruption by excluding direct investment in issuers deemed to have failed to comply with the 10 UN Global Compact Principles, through application of the BlackRock EMEA Baseline Screens. The definition of “involved” in relation to each activity may be based on generating or deriving a revenue from the activity that exceeds a percentage of revenue or a defined total revenue threshold, or any exposure to the activity regardless of the amount of revenue received.

The Fund promotes social characteristics related to the reduction of societal controversies by excluding issuers with a ‘red’ MSCI ESG controversy flag (based on an MSCI ESG controversy score of 0) in relation to social issues, including, for example, human rights, labour management relations, discrimination and workforce diversity.

Finally, the Fund also aims to promote social characteristics relating to wellbeing of society as a whole by minimising exposures to issuers with lower MSCI ESG ratings (described above) based on certain social themes relating to for example, providing access to basic services, community relations, data privacy and security, human capital, health and safety and product governance.

To the extent the Fund holds government bonds, the Fund will instead promote social characteristics relating to supporting the UN Security Council’s efforts on political settlement of conflicts, nuclear non-proliferation, and counter-terrorism by excluding investment in bonds issued by government issuers subject to UNSC Trade Sanctions.

D. Investment strategy

The investment objective of the Fund is to provide a return in line with money market rates consistent with preservation of principal and liquidity by the maintenance of a portfolio of High Credit Quality short term “money market” instruments.

The investment policy of the Fund is to invest in a broad range of Euro denominated High Credit Quality fixed income securities (such as bonds) and money market instruments (i.e. debt securities with short term maturities) such as securities, instruments and obligations that may be available in the relevant markets (both within and outside the Eurozone) and in cash. The Fund will invest only in securities with a maturity at issuance or residual term to maturity of 397 days or less. At least 7.5% of the Fund’s assets will be daily maturing and at least 15% of the Fund’s assets will be weekly maturing (provided that units or shares in other money market funds may be included in the weekly maturity assets, up to 7.5%, provided they can be redeemed and settled within five working days). The Fund will maintain a weighted average maturity of 60 days or less and a weighted average life of 120 days or less.

Subject always to investing in such assets as required for the Fund to meet its investment objective, the Investment Manager will manage the Fund to promote environmental and social characteristics based on environmental and social criteria set out in the binding elements section below.

The binding elements of the investment strategy are as follows:
1. Ensure that more than 90% of the issuers of securities in which the Fund invests shall be ESG rated or have been analysed for ESG purposes.
2. Maintain that at least 80% of the Fund’s assets (which are not investments in government and public securities and instruments) have above average environmental practices as determined by MSCI or such other external ESG research provider used by the Investment Manager from time to time. MSCI rank corporate issuers based on an issuers’ overall MSCI environmental score. Corporate issuers that are ranked by MSCI to be in the first or second quartile for the MSCI environmental score are eligible for investment by the Fund (for example, corporate issuers that have low carbon emissions, sustainable use of natural resources, responsible waste management practices and use of renewable energy).
3. Maintain that the Fund will have 20% lower greenhouse gas emissions (measured using data from MSCI) than its Investment Universe (this universe comprises of approved issuers that comply with the money market fund credit assessment process).
4. Subject always to investing in such assets as required for the Fund to meet its investment objective, the Investment Manager will manage the Fund to promote environmental and social characteristics based on the environmental and social criteria set out below. When selecting the Fund’s investments, the Investment Manager will, as a non-financial objective, exclude direct investment in issuers of money market instruments which, at the time of investment: i) derive 5% or more of their revenues from fossil fuel mining, exploration and/or refinement; ii) have a MSCI ESG rating of CCC; iii) have a MSCI Controversy Score of ‘0’; iv) have, in the case of any Supranational and Agency Entities, an MSCI ESG rating of B or below; or v) are caught by the BlackRock EMEA Baseline Screens (as described below and in Appendix III).
5. BlackRock EMEA Baseline Screens: The Investment Manager will seek to limit and/or exclude direct investment (as applicable) in corporate issuers which, at the time of purchase, in the opinion of the Investment Manager, have been deemed to have failed to comply with UN Global Compact Principles or have exposure to, or ties with, certain sectors (in some cases subject to specific revenue thresholds): i) the production of certain types of controversial weapons; ii) the distribution or production of firearms or small arms ammunition intended for retail to civilians; iii) the extraction of certain types of fossil fuel and/or the generation of power from them; or iv) the production of tobacco products or certain activities in relation to tobacco-related products.
6. A full list of the BlackRock EMEA Baseline Screens limits and/or exclusions being applied by Investment Managers at any time (including any specific threshold criteria) is available at https://www.blackrock.com/corporate/ literature/publication/blackrock-baselinescreens-in-europe-middleeast-and-africa.pdf

The binding elements set out above do not apply when selecting the Fund’s investments issued by governments. Instead, the binding element will be the application of UNSC Trade Sanctions to the government issuers of the bonds the Fund holds.

Consideration of principal adverse impacts on sustainability factors

The Fund considers PAIs on sustainability factors through the application of its carbon reduction target and its exclusionary policy.

The Fund takes into account the following PAIs:
• GHG Emissions
• Carbon footprint
• GHG intensity of investee companies.
• Exposure to companies active in the fossil fuel sector
• Activities negatively affecting biodiversity sensitive areas
• Emissions to water
• Hazardous waste ratio
• Violations of UN Global Compact principles and Organisation for Economic Cooperation and Development (OECD) Guidelines for Multinational Enterprises
• Exposure to controversial weapons (anti personnel mines, cluster munitions, chemical weapons and biological weapons)

Good governance policy

BlackRock assesses good governance practices of the investee companies by combining proprietary insights and shareholder engagement by the Investment Manager, with data from external ESG research providers. BlackRock uses data from external ESG research providers to initially identify issuers which may not have satisfactory governance practices in relation to key performance indicators (KPIs) related to sound management structure, employee relations, remuneration of staff and tax compliance.

Where issuers are identified as potentially having issues with regards to good governance, the issuers are reviewed to ensure that, where the Investment Manager agrees with this external assessment, the Investment Manager is satisfied that the issuer has either taken remediation actions or will take remedial actions within a reasonable time frame based on the Investment Manager’s direct engagement with the issuer. The Investment Manager may also decide to reduce exposure to such issuers.

E. Proportion of Investments

A minimum of 80% of the Fund's total assets will be invested in investments that are aligned with the environmental and/or social characteristics.

The Fund may invest up to 20% of its total assets in other investments.

The Fund may use derivatives for hedging purposes only, not to attain environmental or social characteristics.

The Fund does not currently commit to invest more than 0% of its assets in Sustainable Investments with an environmental objective aligned with the EU Taxonomy.

The Fund does not currently commit to invest in fossil gas and/or nuclear energy related activities that comply with the EU Taxonomy.

The Fund does not commit to making investments in transitional and enabling activities. 

The Fund does not commit to holding Sustainable Investments.

Other holdings are limited to 20% and may include derivatives, cash held with the custodian and fixed income transferable securities (also known as debt securities) issued by governments.

These investments may be used for investment purposes in pursuit of the Fund’s (non ESG) investment objective, for the purposes of liquidity management and/or hedging.

No other holdings are considered against minimum environmental or social safeguards.

F. Monitoring of enviromental or social characteristics

BlackRock has developed a highly automated compliance process to help ensure that the Fund is managed in accordance with its stated investment guidelines and applicable regulatory requirements. This includes monitoring of the environmental or social characteristics of the Fund in accordance with the relevant methodology as described in ‘Section G – Methodologies’.

Portfolio Managers have the primary responsibility for complying with the contractual terms of the prospectus and other governing documents for the Fund and are supported by Aladdin, BlackRock’s portfolio and risk management software.

The Portfolio Compliance Group (“PCG”), a group within BlackRock’s Business Operations, is responsible for the coding of the Fund’s investment restrictions, that are capable of being coded, within BlackRock’s pre and post trade compliance monitoring system in Aladdin. Where an investment restriction cannot be coded, a manual process is established for guidelines testing.

Pre-Trade & Post Trade Monitoring

When a trade or order is created, the transaction is reviewed against the Fund’s investment guidelines by the front-end compliance system on a real time basis prior to execution. If a non-compliant condition is detected, the trade or order will be unable to progress further.

Compliance tests are also run on a post trade basis overnight based on the end-of-day positions and reported on a T+1 basis. Compliance exceptions and warnings are identified and escalated for investigation to relevant investment professionals, who will engage with relevant subject matter experts as appropriate to resolve. Identification and investigation of potential items is recorded on an electronic system that contains a comprehensive workflow which provides an audit trail. Appropriate corrective action will be taken as needed to resolve exceptions.

The monitoring of certain ESG characteristics may not be able to be automated due to system functionality or data limitations. Such ESG characteristics are subject to periodic review and monitoring, to ensure that the product adheres to the related commitments.

Breaches are reported as required under our regulatory obligations to the revelant management company, auditor, depositary and regulator.

Where BlackRock delegates part of the management of a Fund to a third-party manager, the third-party manager is responsible for ensuring compliance with the investment guidelines and investment restrictions as per the agreed Investment Management Agreement in place, including those pertaining to the environmental or social characteristics for the Fund. The investment restrictions pertaining to the environmental or social characteristics are generally communicated to the third-party manager which may updated by BlackRock from time to time in line with the environmental and social characteristics of the Fund. When the third-party manager runs a passive strategy, the third-party manager may also monitor whether the environmental or social characteristics are met by tracking a benchmark index embedding these characteristics in its methodology. BlackRock receives a daily feed of the positions held by the third-party manager and runs post-trade compliance checks in accordance with the back-end compliance process previously described. BlackRock also undertakes periodic due diligence on third party manager to ensure the monitoring frameworks in place remain appropriate.

G. Methodologies

BlackRock has adopted the following methodologies in respect of this Fund:
1. The Fund uses MSCI ESG scoring as a means of assessing issuers' exposure to and management of environmental and social risks and opportunities. Further details on the MSCI ESG scoring methodology are available at: https://www.msci.com/our-solutions/esg-investing/esg-ratings
2. The Fund measures the greenhouse gas emissions intensity of the portfolio. Further details on the methodology for calculating greenhouse gas emissions intensity are set out in 'Section C – Environmental or social characteristics' above.
3. The Fund applies a set of exclusionary screens. Further details on the methodology of the exclusionary screens are set out in 'Section C – Environmental or social characteristics' above.

H. Data sources and processing

Data Sources

BlackRock Portfolio Managers have access to research, data, tools, and analytics to integrate ESG insights into their investment process. Aladdin is the operating system that connects the data, people, and technology necessary to manage portfolios in real time, as well as the engine behind BlackRock’s ESG analytics and reporting capabilities. BlackRock’s Portfolio Managers use Aladdin to make investment decisions, monitor portfolios and to access material ESG insights that can inform the investment process to attain ESG characteristics of the Fund.

ESG datasets are sourced from external third-party data providers, including but not limited to MSCI, Sustainalytics, Refinitiv, S&P and Clarity AI. These datasets may include headline ESG scores, carbon emissions data, business involvement metrics or controversies and have been incorporated into Aladdin tools that are available to Portfolio Managers and employed in BlackRock investment strategies. Such tools support the full investment process, from research, to portfolio construction and modelling, to reporting.

Measures taken to ensure Data Quality

BlackRock applies a comprehensive due diligence process to evaluate provider offerings with highly targeted methodology reviews and coverage assessments based on the sustainable investment strategy (and the environmental and social characteristics or sustainable objective) of the product. Our process entails both qualitative and quantitative analysis to assess the suitability of data products in line with regulatory standards as applicable.

We assess ESG providers and data across five core areas outlined below:
1. Data Collection: this includes but is not limited to assessing the data providers underlying data sources, technology used to capture data, process to identify misinformation and any use of machine learning or human data collection approaches. We will also consider planned improvements
2. Data Coverage: our assessment includes but is not limited to the extent to which a data package provides coverage across our investible universe of issuers and asset classes. This will include consideration of the treatment of parent companies and their subsidiaries as well as use of estimated data or reported data
3. Methodology: our assessment includes but is not limited to consideration of the third-party providers methodologies employed, including considering the collection and calculation approaches, alignment to industry or regulatory standards or frameworks, materiality thresholds and their approach to data gaps.,
4. Data Verification: our assessment will includes but is not limited to the third party providers’ approaches to verification of data collected and quality assurance processes including their engagement with issuers
5. Operations: we will assess a variety of aspects of a data vendors operations, including but not limited to their policies and procedures (including consideration of any conflicts of interest) the size and experience of their data research teams, their training programs, and their use of third-party outsourcers

Additionally, BlackRock, actively participates in relevant provider consultations regarding proposed changes to methodologies as they pertain to third party data sets or index methodologies and submits considered feedback and recommendations to data provider technical teams. BlackRock often has ongoing engagement with ESG data providers including index providers to keep abreast of industry developments.

How data is processed

At BlackRock, our internal processes are focused on delivering high-quality standardized and consistent data to be used by investment professionals and for transparency and reporting purposes. Data, including ESG data, received through our existing interfaces, and then processed through a series of quality control and completeness checks which seeks to ensure that data is of a high-quality before being made available for use downstream within BlackRock systems and applications, such as Aladdin. BlackRock’s integrated technology enables us to compile data about issuers and investments across a variety of environmental, social and governance metrics and a variety of data providers and make those available to investment teams and other support and control functions such as risk management.

Use of Estimated Data

BlackRock strives to capture as much reported data from companies via 3rd party data providers as practicable, however, industry standards around disclosure frameworks are still evolving, particularly with respect to forward looking indicators. As a result, in certain cases we rely on estimated or proxy measures from data providers to cover our broad investible universe of issuers. Due to current challenges in the data landscape, while BlackRock relies on material amount of estimated data across our investible universe, the levels of which may vary from data set to data set, we seek to ensure that use of estimates is in line with regulatory guidance and that we have necessary documentation and transparency from data providers on their methodologies. BlackRock recognizes the importance in improving its data quality and data coverage and continues to evolve the data sets available to its investment professionals and other teams. Where required by local country-level regulations, funds may state explicit data coverage levels.

I. Limitations to methodologies and data

Limitations to Methodology

Sustainable investing is an evolving space, both in terms of industry understanding but also the regulatory frameworks on both a regional and global basis. BlackRock continues to monitor developments in the EU's ongoing implementation of its framework for sustainable investing and is seeking to evolve its investment methodologies to ensure alignment as the regulatory environment changes. As a result, BlackRock may update these disclosures, and the methodologies and sources of data used, at any time in the future as market practice evolves or further regulatory guidance becomes available.

The UN Sustainable Development Goals and sub-targets are used by BlackRock as a list of environmental and/or social objectives. Any assessment will be undertaken strictly in accordance with the methodology set out in the Prospectus. Assumptions associated with the conventional use of the SDGs are not considered as part of the assessment including but not limited to applicable geographical limitations and those commitments that may be limited by time or scope, such as goals that may be applicable only to governments.

Limitations in relation to the data sources are noted below.

Limitations to Data

ESG data sets are constantly changing and improving as disclosure standards, regulatory frameworks and industry practice evolve. BlackRock continues to work with a broad range of market participants to improve data quality.

Whilst each ESG metric may come with its own individual limitations, data limitations may broadly be considered to include, but not be limited to:
• Lack of availability of certain ESG metrics due to differing reporting and disclosure standards impacting issuers, geographies or sectors
• Nascent statutory corporate reporting standards regarding sustainability leading to differences in the extent to which companies themselves can report against regulatory criteria and therefore some metric coverage levels may be low
• Inconsistent use and levels of reported vs estimated ESG data across different data providers, taken at varied time periods which makes comparability a challenge.
• Estimated data by its nature may vary from realized figures due to the assumptions or hypothesis employed by data providers.
• Differing views or assessments of issuers due to differing provider methodologies or use of subjective criteria
• Most corporate ESG reporting and disclosure takes place on an annual basis and takes significant time to produce meaning that this data is produced on a lag relative to financial data. There may also inconsistent data refresh frequencies across different data providers incorporating such data into their data sets.
• Coverage and applicability of data across asset classes and indicators may vary
• Forward looking data, such as climate related targets may vary significantly from historic and current point in time metrics.

For more information about how metrics that are presented with sustainability indicators are calculated, please see the Fund's annual report.

J. Due Diligence

BlackRock applies a high standard of due diligence in the selection and ongoing monitoring of investments made by the Fund for the purpose of compliance with the investment, liquidity and risk guidelines of the Fund, as well as the sustainability risk and ESG criteria and general performance. Portfolio Managers are subject to pre and post trade controls within the investment platform where the funds promote environmental or social characteristics, integrate sustainability into the investment process in a binding manner or have a sustainable investment objective. The Investment Oversight team conducts due diligence engagement with the portfolio managers and oversees internal restrictions that may expand upon requirements set out in the fund prospectus. The Portfolio Managers also comply with related EMEA policies, including Investment Due Diligence policies which have been updated to integrate sustainability risk. Legal and Compliance have implemented a framework to ensure that the relevant policies and procedures are adopted and complied with by all employees, including Portfolio Managers.

The Investment Manager integrates sustainability risks into the investment due diligence process of the Fund. The portfolio managers of the Fund are primarily responsible for considering sustainability risks. They are subject to an oversight framework within the Investment Manager and BlackRock's risk management function, RQA group also provides independent reviews of sustainability risks and the compliance team provides further oversight and monitors the ESG requirements relevant to each fund and the investment restrictions for each fund. RQA, serves as the second line of defence in BlackRock’s risk management framework. RQA is responsible for BlackRock’s Investment and Enterprise risk management framework which includes oversight of sustainability-related investment risks. RQA Investment Risk conducts regular reviews with portfolio managers to ensure investment teams are advised of relevant sustainability risks, complementing the first-line monitoring and oversight of sustainability considerations across our investment platform. RQA also has a dedicated Sustainability Risk Team that partners with risk managers and businesses to reinforce this constructive engagement. RQA collaborates with working groups throughout the Investments Platform and with Aladdin Sustainability Lab to advance the firm’s sustainability toolkit through consultation on firmwide data, modelling, methodologies, and analytics. For further information on sustainability risks, please refer to BlackRock's sustainability risk disclosure available here. In addition, BlackRock makes data relating to principal adverse impacts available to all portfolio managers and BlackRock integrates consideration of the principle adverse impacts of investment decisions on sustainability factors in the investment due diligence process. For further information, please see ‘Section D – Investment strategy’ above.

K. Engagement Policies

The Fund

The Fund does not use engagement as a means of meeting its binding commitments to environmental or social characteristics or sustainable investment objectives. Engagement may form part of the Due Diligence carried out by the investment team for funds pursuing Cash Management investment strategies in order to assess how companies manage ESG risks and opportunities and how these impact company performance. Where applicable, we use engagement to discuss concerns, understand opportunities and share constructive feedback, based on the view that material ESG issues are intractably tied to a business’s long term strategy and fundamental value. Engagement may be undertaken in collaboration with the BlackRock’s Investment Stewardship team, however this is not always the case and can be undertaken directly.

General

Engagement with companies in which we invest our clients’ assets occurs at multiple levels within BlackRock. 

Where engagement is specifically identified by a particular portfolio management team as one of the means by which they seek to demonstrate a commitment to environment, social and governance issues within the context of SFDR, the methods by which the effectiveness of such engagement policy and the ways in which such an engagement policy may be adapted in the event that they do not achieve the desired impact (usually expressed as a reduction in specified principal adverse indicators) would be described in the prospectus and website disclosures particular to that fund. 

Where investment teams chooses to leverage engagement, this  can take a variety of forms but, in essence, the portfolio management team would seek to have regular and continuing dialogue with executives or board directors of engaged investee companies to advance sound governance and sustainable business practices targeted at the identified ESG characteristics and principal adverse indicators, as well as to understand the effectiveness of the company’s management and oversight of activities designed to address the identified ESG issues. Engagement also allows the portfolio management team to provide feedback on company practices and disclosures.

Where a relevant portfolio management team has concerns about a company’s approach to the identified ESG characteristics and/or principal adverse indicators, they may choose to explain their expectations to the company’s board or management and may signal through voting at general meetings that they have outstanding concerns, generally by voting against the re-election of directors they view as having responsibility for improvements in the identified ESG characteristics or principal adverse indicators.

Separate from the activities of any particular portfolio management team, at the highest level, as part of its fiduciary approach, BlackRock has determined that it is in the best long-term interest of its clients to promote sound corporate governance as an informed, engaged shareholder. At BlackRock, this is the responsibility of BlackRock Investment Stewardship. Principally through the work of BIS team, BlackRock meets the requirements in the Shareholder Rights Directive II (‘SRD II”) relating to engagement with public companies and other parties in the investment ecosystem.  A copy of BlackRock’s SRD II engagement policy can be found at https://www.blackrock.com/corporate/literature/publication/blk-shareholder-rights-directiveii-engagement-policy-2022.pdf.

BlackRock’s approach to investment stewardship is outlined in the BIS Global Principles and market-level voting guidelines. The BIS Global Principles set out our stewardship philosophy and our views on corporate governance and sustainable business practices that support long-term value creation by companies. We recognize that accepted standards and norms of corporate governance differ between markets; however, we believe there are certain fundamental elements of governance practice that are intrinsic globally to a company’s ability to create long-term value. Our market-specific voting guidelines provide detail on how BIS implements the Global Principles – taking into consideration local market standards and norms – and inform our voting decisions in relation to specific ballot items for shareholder meetings.  BlackRock’s overall approach to investment stewardship and engagement can be found at: https://www.blackrock.com/uk/professionals/solutions/shareholder-rights-directive and https://www.blackrock.com/corporate/about-us/investment-stewardship

In undertaking its engagement, BIS may focus on particular ESG themes, which are outlined in BlackRock’s voting priorities https://www.blackrock.com/corporate/literature/publication/blk-stewardship-priorities-final.pdf

L. Designated reference benchmark

There is no specific index designated as a reference benchmark to determine whether this financial product is aligned with the environmental and/or social characteristics that it promotes. However, please note that the Liquidity Funds Investment Universe is used to compare certain ESG characteristics promoted by the Fund.