Benson Adenuga

Excluded Activities are:

1. the mining or extracting of precious metals and other geological materials (but excluding services to companies engaged in such activities);
2. the production of, or trade in:
   • hazardous chemicals, pharmaceuticals, pesticides and wastes, as specified in the 2004 Stockholm Convention on Persistent Organic Pollutants; the 2004 Rotterdam Convention on the Prior Informed Consent Procedure for Certain Hazardous Chemicals and Pesticides in International Trade; the 1992 Basel Convention on the Control of Transboundary Movements of Hazardous Wastes and their Disposal and WHO Recommended Classification of Pesticides by Hazard Class 1a (extremely hazardous); or 1b (highly hazardous);
   • ozone depleting substances, as specified in the 1999 Montreal Protocol on Substances that Deplete the Ozone Layer;
   • endangered or protected wildlife or wildlife products, as specified in the 1975 Convention on International Trade in Endangered Species or Wild Flora and Fauna;
   • any other product or activity deemed illegal under applicable local or national laws or regulations or subject to internationally agreed phase-outs or bans as defined in global conventions and agreements;
   • arms (i.e. weapons, munitions or nuclear products, primarily designated for military purposes); or
   • radioactive materials (excluding medical equipment, quality control (measurement) equipment, civilian power generation and any equipment in which the radioactive source could reasonably be considered to be trivial or adequately shielded);
3. the production of, use of, or trade in unbonded asbestos fibres;
4. unsustainable fishing methods such as blast fishing and drift net fishing in the marine environment using nets in excess of 2.5 kilometres in length;
5. prostitution; and
6. any of the following, to the extent that the activities represent more than 10% of the Group’s underlying portfolio volumes:
   • gambling, gaming casinos and equivalent enterprises;
   • tobacco or tobacco related products (except where the Group proposes to cease such activities completely within a period agreed with BII); or
   • pornography.
7. speculative and/or unregulated use of cryptocurrencies;
8. AI where it poses “unacceptable risk” as defined in the EU AI Act 2021;
9. social media targeting children and other vulnerable people, and dating apps;
10. products and services primarily designed for national security and intelligence services (e.g., NSO Group) where there is a reasonable risk of human rights abuses;
11. any business if alcoholic beverages (except beer and wine) represent a substantial portion of such business;
12. animal and human cloning, or;
13. prisons and detention centres;
14. any healthcare facility dedicated to high end cosmetic procedures and/or surgeries; and any private multi-specialty hospital that does not satisfy at least one of the Hospital Investment Criteria.
15. Any educational institution or facility where companies are primarily involved in private, fee-charging schools that provide education from kindergarten (or equivalent) to the final year prior to tertiary level education, or companies that primarily provide educational services to private, fee-charging schools such that they resemble private fee-charging schools (“Barred K-12 Activity”).

The “Hospital Investment Criteria” shall be deemed satisfied if, at the date of the investment, the private multi-specialty hospital either significantly serves or demonstrates an intention to serve: (i) patients in the target segment of government payor public schemes; or (ii) patients living on US$ 8.00 or less per day. Investments in single specialty hospitals, and primary and secondary care chains are not subject to the Hospital Investment Criteria. ‘Primarily’ for purposes of 15 above ‎is defined as where (i) for companies, more than 10% of its consolidated balance sheet or earnings, or (ii) for financial institutions, more than 10% of its portfolio volumes, comes from a Barred K-12 Activity.