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MetLife Investment Management RIAIF ICAV - SFDR Article 10 website disclosures

MetLife European Private Debt Fund I

MetLife European Private Debt Fund II

Best Execution Disclosure

18 November 2025

In accordance with the regulatory requirements set out in the Markets in Financial Instruments Directive 2014/65/EU (“MiFID II”) and the Commission Delegated Regulation 2017/565 ("MiFID CDR”), on an annual basis, MetLife Investment Management Europe Limited (“MIMEL” or the “Company”) is required to summarise and make public, for each class of financial instruments, the top five execution venues in terms of trading volumes where MIMEL executed client orders in the preceding year, as well as information on the quality of the execution obtained.

The Company’s clients ("Clients”, each a “Client”) for the purposes of this disclosure are entities with which it has a segregated mandate, whether a discretionary investment management (“Individual Portfolios”, each being an “Individual Portfolio”) or non-discretionary investment advisory mandate, and entities to which it provides the services of the reception and transmission of orders (collectively hereinafter “MiFID Services Clients”, which receive “MIFID Services”), in addition to AIF and UCITS collective investment schemes (“Funds”, each being a “Fund”), such activity also being referred to as collective portfolio management or “CPM” services.

In accordance with S.I. No. 352/2011 - European Communities (Undertakings for Collective Investment in Transferable Securities) Regulations 2011 (the “UCITS Regulations”) and the Commission Delegated Regulation (EU) No 231/2013 ("AIFMD Level II Regulation”), the Company must also make available appropriate information on its Best Execution Policy to investors in a UCITS or AIF.

This disclosure thus summarises how MIMEL will seek to achieve best execution for its clients when providing investment services to Individual Portfolios or in its management of AIFs and UCITs.

For the purposes of this disclosure, ‘executing’ shall be taken to mean executing orders or placing orders for execution arising from decisions to deal by either MIMEL, a delegate (or sub-delegate) of MIMEL, or the reception and transmission of client orders by MIMEL with other entities for execution.

Scope and Application of Best Execution Requirements

Where it is established that a duty of best execution is owed to a particular client, including the nature of this duty, the obligation to deliver the best possible result when executing Client orders applies in relation to all types of “Financial instruments” referenced in Annex I, Section C of MiFID II.

However, given the differences in market structures or the structure of Financial Instruments, it may be difficult to identify and apply a uniform standard of and procedure for best execution that would be valid and effective for all classes of instrument. Best execution obligations will therefore be applied in a manner that takes into account the different circumstances associated with the execution of orders related to particular types of Financial Instruments.

When the Company is acting as investment manager and decides to deal in financial instruments on behalf of a Client and / or when the Company is providing the service of reception and transmission of orders, it must act in accordance with the best interests of the Client when placing orders with other entities for execution. In the context of managing Individual Portfolios, when executing Client Orders, the Company is obliged to take all “sufficient steps” to obtain the best possible result for its client.

Similarly, in the context of the management of a Fund’s portfolio, the Company is required to take all reasonable steps to obtain the best possible result for a Fund when:

a) executing decisions to deal on behalf of the Fund; or

b) placing orders to deal on behalf of the Fund with other entities for execution.1 The Company considers the requirement for “sufficient” steps represents a higher bar for compliance than “reasonable” step

Annual Publication of Data – Top Execution Venues and Execution Quality

In respect of the Individual Portfolios to which it provides investment services, on an annual basis, the Company will summarise and make public, for each class of Financial Instrument, the top five execution venues in terms of trading volumes where the Company executed Client orders in the preceding year, as well as information on the quality of the execution obtained.

As at the date of publication of this website disclosure, the Company does not have a live discretionary investment management mandate with a MiFID Services Client dealing in Financial Instruments, therefore no disclosures are currently available in respect of each class of financial instrument, the top five execution venues in terms of trading volumes where the Company executed Client orders in the preceding year, as well as information on the quality of the execution obtained.

The Company will also publish on at least an annual basis and make public data regarding the quality of execution of transactions in respect of Individual Portfolios and provide confirmation of whether MIMEL has executed an average of less than one trade per business day in the previous year in that class of Financial Instruments.

As at the date of publication of this website disclosure, the Company does not have a live discretionary investment management mandate with a MiFID Services Client dealing in Financial Instruments, therefore such data is not currently available for disclosure.

Order Execution Process and General Execution Factors

The Company has implemented a Best Execution Policy which establishes a process by which the Company, or appointed delegates, will determine the relative importance of the execution factors. The relative importance that the Company gives to those execution factors must be designed to obtain the best possible result for its Client. The execution factors include: (i) price; (ii) costs; (iii) speed; (iii) likelihood of execution and settlement; (iv) size; (v) nature; (vi) any other consideration relevant to the execution of a client order.

1 Article 27 and 28 of Commission Delegated Regulations (EU) No. 231/2013 of 19 December 2012 (“AIFMD Level 2 Regulation)”, and paragraph 13 of Schedule 5 of European Communities (Undertakings for Collective Investment in Transferable Securities) Regulations 2011 (the “UCITS Regulations”).

The Company or delegate ensures that, when determining the relative importance of the above factors, it has regard to the objectives, investment policy and risks specific to a Fund (as indicated in the prospectus or, as the case may be, in the trust deed, deed of constitution or articles of the Fund), or any investment management or advisory agreement with a Client.

(i) Price:

The market price at which the order is executed. This is usually the most important Execution Factor, which is therefore often assigned a high weighting for most client activity. This relates to the bid/offer price that is quoted for the value of the transaction to be executed.

(ii) Costs

This represents the cost covering the risks incurred by the Company by entering into a transaction, such as: a) fees or commissions b) capital requirements; c) liquidity costs; d) cost of hedging our risks resulting from those transactions. Margins and charges will be commensurate with the nature of the market, the characteristics of the transaction and the Client. Costs shall also include any additional charges that may be incurred in executing the order in a particular way.

(iii) Speed of execution

In some markets, price volatility may mean that the timeliness of execution is a priority, whereas, in other markets that have low liquidity and high latency it may be necessary to execute your order over a longer period of time. This can be particularly important in fast moving markets.

(iv) Likelihood of execution and settlement

The likelihood that the Company can source adequate liquidity with sufficient depth of market, having necessary credit facilities in place to guarantee settlement, especially for some OTC products where there is no formalised market or settlement infrastructure.

(v) Size and nature of the transaction

Ensuring that orders are executed in a manner which is suitable to the size requested and does not result in an adverse effect on the market. The way the Company executes an unusual order (for example, one that is larger than the normal market size or has unusual features such as an extended or shortened settlement period) may differ from the way the Company executes a standard order.

In certain circumstances (e.g., for some Client orders, Financial Instruments, or markets), the Company’s policy may appropriately determine that other execution factors are more important than price in obtaining the best possible execution result.

Approved Counterparty List and Execution Venues

The MetLife Global Risk Management Credit Department (“GRM”) maintains a complete listing of approved broker/dealers and derivatives counterparties (the “Counterparty Approved List”). All counterparties must be approved in accordance with the MIM Trading Counterparty Approval and Monitoring Policy. The Counterparty Approved List specifies the types of transactions that can be conducted with each counterparty or broker and any special limitations applicable to a counterparty.

In determining whether a particular broker, counterparty or execution venue is likely to provide best execution in a particular transaction, the factors below are taken into account, broken down per applicable asset class.

A list of the execution venues on which the Company places significant reliance for its Individual Portfolios (where relevant) will be published on an annual basis, as described above, or will be disclosed on this website where any material changes occur to the Company’s overarching arrangements to achieve best execution.

As at the date of publication of this website disclosure, the Company does not have a live discretionary investment management mandate with a MiFID Services Client dealing in Financial Instruments, therefore such data is not currently available for disclosure.

RTS 27 (Delegated Regulation (EU) 2017/575) is not applicable as MIMEL is not an execution venue and will not use the output of a consolidated tape provider.

Execution Factors Particular to Equity and Public Fixed Income Securities Transactions

The guiding principle in selecting a counterparty or broker from the Counterparty Approved List for a particular transaction is to seek the best possible result for the Client, taking into account:

  • the overall costs of the trade (i.e., net price paid or received) including commissions (if applicable), mark-ups, mark-downs or spreads in the context of the trader’s knowledge of current pricing and transaction costs; 
  • the nature of the market for the security or instrument;
  • the size and difficulty of the order;
  • the execution experience of the counterparty with respect to specific markets or securities;
  • confidentiality;
  • the competitiveness of the commission;
  • the certainty of execution;
  • the counterparty’s capital clearance and settlement capabilities;
  • desired timing of the trade;
  • reputation, financial strength, and stability;
  • block trading capabilities;
  • access to underwritten offerings and secondary markets.

Execution Factors Particular to Derivatives Transactions

The selection of an execution venue can be contingent on market specific factors, Client guidelines and investment strategy/product considerations. Execution venues may include, without limitation: principal traders and market makers (e.g., broker/dealers), multi-lateral trading facilities (including electronic trading platforms) ("MTFs”), regulated markets or other liquidity providers.

When selecting a counterparty or broker, traders must choose the counterparty or broker from the Counterparty Approved List and ensure that any other criteria agreed with a Client have been satisfied.

The guiding principle in executing a derivatives transaction is to take all sufficient steps to achieve the best possible result for the Client, with due regard to the factors listed below:

  • price and total costs of trade execution including exchange and clearinghouse fees and costs of collateralisation; 
  • the size and complexity of the derivative to be transacted; 
  • the current market for the derivative instrument, including trading/market-making liquidity and desired timing of the derivative transaction; 
  • confidentiality; 
  • derivative product and execution venue; and 
  • the following factors in relation to counterparties, brokers and execution venues:
    • applicable credit limits of the counterparty or broker with the execution facility;
    • reliability and promptness of trade executions, including the execution experience of the counterparty, broker or execution facility with respect to the derivative instruments to be traded; and
    • reliability of transaction processing and settlement.

Other Assets

Other asset classes such as private debt, real estate and private equity are not Financial Instruments and therefore not within scope of best execution requirements. However, the Company acts in the best interests of its Clients and seeks to maximise overall Client results in the investment process, taking into account appropriate quantitative and qualitative factors.

Managing Conflicts of Interest

MIMEL takes all appropriate steps to prevent conflicts of interest from constituting or giving rise to a risk of damage to the interests of its Clients or investors in its Funds. Where the potential risk cannot be prevented, MIMEL must disclose this to its Client before providing services.

Trading will be directed to counterparties that are demonstrably able to deliver best execution on a consistent basis.

MIMEL will conduct periodic monitoring to verify that its best execution arrangements are adequate and working effectively without prejudicing the interests of Clients.

Ongoing Monitoring and Review

The Company, and its delegates as applicable, will monitor the execution quality obtained and the quality and appropriateness of its execution arrangements and policies, to identify circumstances under which changes may be appropriate.

The Company, and its delegates as applicable, will monitor the execution quality obtained and the quality and appropriateness of its execution arrangements and policies, to identify circumstances under which changes may be appropriate.

The Company reviews its Best Execution Policy and framework on an annual basis, or more frequently if a material change occurs that may impact MIMEL’s ability to continue to obtain the best possible execution quality for its Clients on a consistent basis following the existing arrangements. Any deficiencies identified must be appropriately remediated.

The Company will notify all Clients of any material changes to the Company’s execution arrangements or its Best Execution Policy.

Client Consent and Specific Instructions

The Company will obtain the prior consent of applicable clients to its Best Execution Policy. Where relevant, the Client will be requested to specifically consent to the provision of information on the Company’s policy via an appropriate website. In this case, the Client will be notified electronically of the address of the website, and the place on the website where the information may be accessed.

In addition, the Company will obtain the prior express consent of applicable Clients before arranging to execute its orders outside a regulated market or a MTF.

Certain fixed income instruments are listed but may trade off-exchange in a dealer market where more liquidity can be sourced, however this may increase the risk of failure by a dealer to deliver or settle orders.

If the Company or its delegate receives a specific execution instruction from a Client, including to use a counterparty with which the Client has established a derivatives trading agreement, the investment manager will execute the order in accordance with that specific instruction. Any specific instructions received from Clients may prevent the investment manager from taking some or all of the steps (or consider the factors) set forth above in implementing its Best Execution Policy, and, therefore, the investment manager will use best efforts to obtain best execution after giving effect to that Client’s instructions in such cases.

Order Execution Policy

A copy of MIMEL’s Best Execution Policy is available upon request. 

For any queries, please contact Rory Caldwell (rory.caldwell@metlife.com), or by writing to:
MetLife Investment Management Europe Limited

20 on Hatch,
Lower Hatch Street,
Dublin 2,
Ireland

MetLife Investment Management RIAIF ICAV - SFDR Article 10 website disclosures

Sustainability-related disclosures

This sustainability-related disclosure ("SRD") is accurate as at: 24 March 2026

This SRD is issued by MetLife Investment Management Europe Limited (the "Manager") and contains information relating specifically to MetLife Sterling Investment Grade Corporate Debt 3 Year Feeder Fund (the “Fund”), an open-ended sub-fund of MetLife Investment Management RIAIF ICAV (the “ICAV”), an umbrella Irish collective asset-management vehicle with segregated liability between sub-funds governed by the laws of Ireland and authorised as a retail investor alternative investment fund under the Alternative Investment Fund Managers Directive 2011, as amended (the "AIFMD") by the Central Bank of Ireland (the "Central Bank"). MetLife Investment Management LLC serves as the investment manager to the Fund (the “Investment Manager”).

Pursuant to the Sustainable Finance Disclosure Regulation (Regulation EU/2019/2088) as amended ("SFDR"), the Fund discloses pursuant to Article 8 of SFDR as a financial product which promotes, among other characteristics, environmental or social characteristics, or a combination of those characteristics, provided that the companies in which the investments are made follow good governance practices.

This SRD has been prepared for the purpose of meeting the website disclosure requirements under Article 10 of SFDR relating to the Fund.

For further details on the Fund and the ICAV, please refer to currently issued version of the ICAV's Prospectus, the Supplement in respect of the Fund and the latest annual report which may be obtained free of charge on request.

Summary
The Fund promotes environmental and social characteristics but does not have sustainable investment as its objective.

The Fund is a feeder fund of the MetLife Sterling Investment Grade Corporate Debt Fund (the “Master Fund”). The information provided here is aligned to the information provided by the Master Fund.

The environmental and social characteristics promoted by the Master Fund are: (1) a reduction in GHG emissions; and (2) a reduction in the use of controversial weapons. As the Fund will invest at least 85% of its assets in the Master Fund, the environmental and social characteristics promoted by the Fund, are also: (1) a reduction in GHG emissions; and (2) a reduction in the use of controversial weapons.

The investment objective of the Fund is to seek to achieve long-term capital growth and income. In order to achieve the investment objective of the Fund, the Fund will invest at least 85% of its assets in the Master Fund and up to 15% in financial derivative instruments (“FDIs”). The Master Fund will seek to achieve its objective by investing primarily in a diversified portfolio of investment grade corporate debt securities either denominated in Sterling or hedged back to Sterling.

The minimum proportion of the investments used to meet the environmental and social characteristics promoted by the Master Fund in accordance with the binding elements of the investment strategy will be 75%, with it being noted that the Master Fund has not committed to making sustainable investments in accordance with Article 2(17) of SFDR. Accordingly, noting that the Fund will invest at least 85% of its assets in the Master Fund, the minimum proportion of investments of the Fund used to meet the environmental and social characteristics promoted by the Fund will be 60% (which is approximately 85% of 75%).

The binding elements of the Fund’s investment strategy used to select the investments to attain the promoted characteristics is that it will invest at least 85% of its assets in the Master Fund. The binding elements of the Master Fund’s investment strategy used to select the investments to attain the promoted characteristics are:

  1. the employment of a carbon constraint of keeping the weighted average carbon intensity (WACI) (carbon intensity being Scope 1 & 2 emissions divided by sales reported by the investee companies) of the Master Fund below that of the Master Fund reference index.
  2. the employment of an exclusion screen in respect of companies exceeding 5% revenue thresholds for any of the following activities: thermal coal extraction; thermal power generation; and oil and gas production.
  3. the employment of an exclusion screen in respect of companies that are involved in the production, sale and/or distribution of nuclear or other controversial weapons (including landmines, cluster weapons, depleted uranium, white phosphorous, incendiary weapons and biological/chemical weapons); and
  4. the consideration of the following PAIs:
    • GHG intensity of investee companies;
    • 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).

The Investment Manager will also consider voluntary PAIs that are deemed applicable based on the relevant issuer and/or sector in which the issuer operates, and where data is readily available.

The Investment Manager will rely on data from MSCI (or a replacement data provider duly chosen and appointed by the Investment Manager) to monitor GHG intensity and the revenue threshold requirements.

There are limitations regarding both methodologies and data. For some exposures, sustainability data is unavailable due to the lack of publicly disclosed information. Disclosure of ESG data is improving year-on-year with more companies publicly disclosing data to support the assessment of the environmental or social characteristics promoted by financial products.

Due diligence on underlying assets is carried out by reference to sustainability data and engagement.

A reference benchmark has not been designated for the purposes of assessing the environmental or social characteristics promoted by the Fund or the Master Fund.

No sustainable investment objective

The Fund promotes environmental or social characteristics but does not have sustainable investment as its objective.

Environmental or social characteristics of the financial product

The Fund is a feeder fund of the MetLife Sterling Investment Grade Corporate Debt Fund (the “Master Fund”). The information provided here is aligned to the information provided by the Master Fund.

The environmental and social characteristics promoted by the Master Fund are: (1) a reduction in GHG emissions; and (2) a reduction in the use of controversial weapons. As the Fund will invest at least 85% of its assets in the Master Fund, the environmental and social characteristics promoted by the Fund, are also: (1) a reduction in GHG emissions; and (2) a reduction in the use of controversial weapons.

Investment strategy

The investment objective of the Fund is to seek to achieve long-term capital growth and income. There is no assurance that such objective will be achieved.

In order to achieve the investment objective of the Fund, the Fund will invest at least 85% of its assets in the Master Fund and up to 15% in financial derivative instruments (“FDIs”). The Master Fund will seek to achieve its objective by investing primarily in a diversified portfolio of investment grade corporate debt securities either denominated in Sterling or hedged back to Sterling.

The Investment Manager believes fixed income markets are efficient with respect to interest rate risk, but regularly misprice securities that are exposed to credit, downgrade, and liquidity risks. The Investment Manager, through investing in the Master Fund, seeks to exploit inefficiencies in the market and provide investors with excess returns to the Master Fund reference index through (i) conducting proprietary, in-depth fundamental research (free cash flow and balance sheet analysis), (ii) analysing capital structures and covenants, (iii) reviewing of management and industry trends, (iv) targeting duration-neutral portfolios and (v) constructing portfolios with attractive risk / reward characteristics.

Further, the Investment Manager employs a carbon constraint and seeks to avoid investments associated with negative externalities through the consideration of PAIs and the application of exclusionary screens.

This strategy is implemented on a continuous basis through the ongoing consideration of the carbon constraint, the PAIs and the application of exclusionary screens, in addition to the requirements for the Investment Manager to manage the portfolio in accordance with the terms of the Supplement.

Proportion of investments

The minimum proportion of the investments used to meet the environmental and social characteristics promoted by the Master Fund in accordance with the binding elements of the investment strategy will be 75%, with it being noted that the Master Fund has not committed to making sustainable investments in accordance with Article 2(17) of SFDR. Accordingly, noting that the Fund will invest at least 85% of its assets in the Master Fund, the minimum proportion of investments of the Fund used to meet the environmental and social characteristics promoted by the Fund will be 60% (which is approximately 85% of 75%).

The purpose of the remaining proportion of the investments within the ‘Other’ category is (a) to adjust the interest rate risk of the Fund’s performance to a duration of approximately 3 years and (b) for liquidity and cash management purposes and no minimum environmental or social safeguards will be applied to these investments.

Monitoring of environmental or social characteristics

The binding elements of the Fund’s investment strategy used to select the investments to attain the promoted characteristics is that it will invest at least 85% of its assets in the Master Fund. The binding elements of the Master Fund’s investment strategy used to select the investments to attain the promoted characteristics are:

  1. the employment of a carbon constraint of keeping weighted average carbon intensity (WACI) (carbon intensity being Scope 1 & 2 emissions divided by sales reported by the investee companies) of the Master Fund below that of the Master Fund reference index.
  2. the employment of an exclusion screen in respect of companies exceeding the following revenue thresholds for specified activities:

    Activity Revenue threshold
    Thermal coal extraction >5%
    Thermal power generation >5%
    Oil and gas production >5%

  3. the employment of an exclusion screen in respect of companies that are involved in the production, sale and/or distribution of nuclear or other controversial weapons (including landmines, cluster weapons, depleted uranium, white phosphorous, incendiary weapons and biological/chemical weapons); and
  4. the consideration of the following PAIs:
    • GHG intensity of investee companies;
    • 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).

The Investment Manager will also consider voluntary PAIs that are deemed applicable based on the relevant issuer and/or sector in which the issuer operates, and where data is readily available.

Methodologies

In order to measure the Fund’s and the Master Fund’s promotion of “a reduction in carbon emissions”, the Master Fund:

  1. employs a carbon constraint of keeping weighted average carbon intensity (WACI) (carbon intensity being Scope 1 & 2 emissions divided by sales reported by the investee companies) of the Master Fund below that of the Master Fund reference index.

    Scope 1 carbon emissions are those from sources owned or controlled by the investee company, typically direct combustion of fuel as in a furnace or vehicle. Scope 2 carbon emissions are those caused by the generation of electricity purchased by the investee company. Absolute carbon emissions are the total emissions of all investee companies, unadjusted for company size or the size of the investment. Carbon intensity is given by absolute carbon emissions divided by some measure of company size, in this case revenue. A portfolio’s WACI is achieved by calculating the carbon intensity (Scope 1 + 2 Emissions / GBPM Revenue) for each portfolio company and calculating the weighted average by portfolio weight. The Investment Manager believes that the way in which it calculates the WACI of both the Master Fund and the Master Fund reference index (i.e., by reference to the total value of sales of each underlying investee company, thereby adjusting for company size), is a more accurate measurement of carbon output, rather than simply measuring carbon output and/or intensity without taking account of the size of the investment. The figure for the WACI of the Master Fund is compared against the figure for the WACI of the Master Fund reference index and this comparison is monitored by the Investment Manager to ensure the figure for the Master Fund remains below that of the Master Fund reference index. If the Investment Manager determines that the Fund is not meeting the WACI requirement based on the data available to it, the Investment Manager will take steps to rebalance the Master Fund's portfolio to meet the WACI requirement, having regard to the overall environmental and social characteristics promoted by the Master Fund. Reporting on the Master Fund’s WACI relative to the Master Fund reference index can be provided by the Investment Manager upon request; and
  2. employs an exclusion screen in respect of companies exceeding the following revenue thresholds for specified activities:

    Activity Revenue threshold
    Thermal coal extraction >5%
    Thermal power generation >5%
    Oil and gas production >5%

In addition, and unrelated to the promoted characteristics of the Master Fund, the Master Fund excludes from its investment universe companies that generate for more than 5% of their revenue from tobacco production, and companies in violation with the UN Global Compact principles.

In order to measure the Master Fund’s promotion of “a reduction in the use of controversial weapons”, the Master Fund employs an exclusion screen in respect of companies that are involved in the production, sale and/or distribution of nuclear or other controversial weapons (including landmines, cluster weapons, depleted uranium, white phosphorous, incendiary weapons and biological/chemical weapons).

In addition, the Investment Manager considers the following PAIs on the Master Fund:

  • GHG intensity of investee companies;
  • violations of UN Global Compact principles and Organisation for Economic Cooperation and Development (OECD) Guidelines for Multinational Enterprise; and
  • exposure to controversial weapons (anti-personnel mines, cluster munitions, chemical weapons and biological weapons).

The Investment Manager will also consider voluntary PAIs that are deemed applicable based on the relevant issuer and/or sector in which the issuer operates, and where data is readily available.

Accordingly, in order to measure the attainment of the promoted characteristics, the Master Fund will determine whether the WACI of the Master Fund is below that of the Master Fund reference index, whether the Master Fund has employed the above referenced exclusionary screens and whether the Master Fund has considered the above referenced PAIs.

As the Fund will invest at least 85% of its assets in the Master Fund, the sustainability indicators that are used to measure the attainment of each of the environmental and social characteristics promoted by the Master Fund, are the same sustainability indicators that are used to measure the attainment of the environmental and social characteristics promoted by the Fund.

Engagement
The Investment Manager's approach to engagement is detailed in the MetLife Investment Management Stewardship Policy (which is available on request). Where possible and deemed necessary, analysts engage in ongoing dialogue with senior leadership of issuers to assess their business model resilience and responsiveness to the environmental, social, and governance factors impacting their business. As engagement is a dynamic process, the Investment Manager reserves the right to adapt its engagement strategy at any time.

Data sources and processing

Data sources used

The Investment Manager will rely on data from MSCI (or a replacement data provider duly chosen and appointed by the Investment Manager) to monitor GHG intensity and the revenue threshold requirements.

Measures taken to ensure data quality

The Investment Manager takes due care in selecting sustainability data providers as well as underlying sustainability research models and datapoints to anticipate and, where possible, mitigate limitations in the sustainability data quality and availability.

Should the Investment Manager determine that data provided to it by MSCI (or such replacement data provider) is incomplete or incorrect, the Investment Manager may use other sources available to it which it reasonably believes to be accurate.

How data is processed

The data referred to above is fed into the Investment Manager’s trading system as pre-trade rules to prevent the Master Fund from trading in the securities of excluded issuers.

Data is processed in accordance with applicable local laws on processing of data and in accordance with the Investment Manager's policies on data processing.

Proportion of data that is estimated

The Investment Manager only uses data as provided from the relevant sources in selecting relevant investments and in applying exclusion criteria. In some cases, the data provided by relevant sources may be estimated and the Investment Manager may also estimate data based on relevant methodologies.

Limitations to methodologies and data

There are limitations regarding both methodologies and data. For some issuers sustainability data is limited and/or unavailable due to the lack of publicly disclosed information. Disclosure of sustainability data is improving year-on-year with more issuers publicly disclosing data to support the assessment of the environmental or social characteristics promoted by financial products.

The data used is provided by external data providers and may contain inaccurate or incomplete data. In case of insufficient data, these data providers may rely on estimates and approximations using internal methodologies that may be subjective. These methodologies may also vary for each data provider. Differences in methodologies may also persist among issuer-reported data.

As the Investment Manager’s process relies on this data when making investment decisions, the data limitations noted above will in turn limit the process and may have an impact on our ability to measure whether the promoted characteristics are met and/or negative consequences for the Master Fund.

However, these challenges may be mitigated by issuer engagement and the Investment Manager does not expect these constraints to have a material impact on its ability to achieve the environmental or social characteristics promoted by the Master Fund.

SFDR seeks to achieve more transparency on how financial market participants integrate sustainability risks into their investment decisions and consideration of adverse sustainability impacts in the investment process. Data constraint is one of the biggest challenges when it comes to providing sustainability related information to end-investors, especially in the case of principal adverse impacts of investment decisions. There are also limitations on sustainability and ESG-related data provided by market participants on comparability.

Due diligence

Due diligence on underlying assets is carried out by reference to:

Sustainability Data

The Investment Manager will use the MSCI data to monitor GHG intensity and the revenue threshold requirements. All sustainability data is dependent on MSCI coverage of the assets of the Fund and the Master Fund.

The Investment Manager will use this MSCI data to ensure it meets the binding environmental or social characteristics promoted by the Fund and the Master Fund.

Engagement

Where possible and deemed necessary, analysts engage in ongoing dialogue with senior leadership of issuers to assess their business model resilience and responsiveness to the environmental, social, and governance risk factors impacting their business.

Engagement policies

Engagement is a core part of the investment process in terms of due diligence and ongoing monitoring.

The Investment Manager intends to engage with issuers to understand their sustainability strategy, obtain better data and facilitate the Fund and Master Fund’s sustainability commitments and reporting.

Should a controversy and/or reason to be concerned about the investment’s alignment to the environmental and/or social characteristics arise, an engagement plan will be compiled to monitor and remediate, where practicable.

Designated reference benchmark

No specific index has been designated as a reference benchmark for the purpose of attaining the environmental and/or social characteristics promoted by the Fund or the Master Fund.

FURTHER INFORMATION

This SRD is issued for information purposes only in accordance with the requirements of SFDR. It is not intended as investment advice and is not an offer or a recommendation about managing or investing assets.

The information contained herein is current as of the date of issuance and is subject to change without notice.

Past performance is not a guarantee or a reliable indicator of future results and an investment could lose value. All investments involve risk, including the possible loss of capital.

The Manager's registered office at 20-on-Hatch, Hatch Street Lower, Dublin 2, Ireland.

The Manager is authorised in Ireland and regulated by the Central Bank.

Sustainability-related disclosures

This sustainability-related disclosure ("SRD") is accurate as at: 24 March 2026

This SRD is issued by MetLife Investment Management Europe Limited (the "Manager") and contains information relating specifically to MetLife Sterling Investment Grade Corporate Debt 5 Year Feeder Fund (the “Fund”), an open-ended sub-fund of MetLife Investment Management RIAIF ICAV (the “ICAV”), an umbrella Irish collective asset-management vehicle with segregated liability between sub-funds governed by the laws of Ireland and authorised as a retail investor alternative investment fund under the Alternative Investment Fund Managers Directive 2011, as amended (the "AIFMD") by the Central Bank of Ireland (the "Central Bank"). MetLife Investment Management LLC serves as the investment manager to the Fund (the “Investment Manager”).

Pursuant to the Sustainable Finance Disclosure Regulation (Regulation EU/2019/2088) as amended ("SFDR"), the Fund discloses pursuant to Article 8 of SFDR as a financial product which promotes, among other characteristics, environmental or social characteristics, or a combination of those characteristics, provided that the companies in which the investments are made follow good governance practices.

This SRD has been prepared for the purpose of meeting the website disclosure requirements under Article 10 of SFDR relating to the Fund.

For further details on the Fund and the ICAV, please refer to currently issued version of the ICAV's Prospectus, the Supplement in respect of the Fund and the latest annual report which may be obtained free of charge on request.

Summary

The Fund promotes environmental and social characteristics but does not have sustainable investment as its objective.

The Fund is a feeder fund of the MetLife Sterling Investment Grade Corporate Debt Fund (the “Master Fund”). The information provided here is aligned to the information provided by the Master Fund.

The environmental and social characteristics promoted by the Master Fund are: (1) a reduction in GHG emissions; and (2) a reduction in the use of controversial weapons. As the Fund will invest at least 85% of its assets in the Master Fund, the environmental and social characteristics promoted by the Fund, are also: (1) a reduction in GHG emissions; and (2) a reduction in the use of controversial weapons.

The investment objective of the Fund is to seek to achieve long-term capital growth and income. In order to achieve the investment objective of the Fund, the Fund will invest at least 85% of its assets in the Master Fund and up to 15% in financial derivative instruments (“FDIs”). The Master Fund will seek to achieve its objective by investing primarily in a diversified portfolio of investment grade corporate debt securities either denominated in Sterling or hedged back to Sterling.

The minimum proportion of the investments used to meet the environmental and social characteristics promoted by the Master Fund in accordance with the binding elements of the investment strategy will be 75%, with it being noted that the Master Fund has not committed to making sustainable investments in accordance with Article 2(17) of SFDR. Accordingly, noting that the Fund will invest at least 85% of its assets in the Master Fund, the minimum proportion of investments of the Fund used to meet the environmental and social characteristics promoted by the Fund will be 60% (which is approximately 85% of 75%).

The binding elements of the Fund’s investment strategy used to select the investments to attain the promoted characteristics is that it will invest at least 85% of its assets in the Master Fund. The binding elements of the Master Fund’s investment strategy used to select the investments to attain the promoted characteristics are:

  1. the employment of a carbon constraint of keeping the weighted average carbon intensity (WACI) (carbon intensity being Scope 1 & 2 emissions divided by sales reported by the investee companies) of the Master Fund below that of the Master Fund reference index.
  2. the employment of an exclusion screen in respect of companies exceeding 5% revenue thresholds for any of the following activities: thermal coal extraction; thermal power generation; and oil and gas production.
  3. the employment of an exclusion screen in respect of companies that are involved in the production, sale and/or distribution of nuclear or other controversial weapons (including landmines, cluster weapons, depleted uranium, white phosphorous, incendiary weapons and biological/chemical weapons); and
  4. the consideration of the following PAIs:
    • GHG intensity of investee companies;
    • 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).

The Investment Manager will also consider voluntary PAIs that are deemed applicable based on the relevant issuer and/or sector in which the issuer operates, and where data is readily available.

The Investment Manager will rely on data from MSCI (or a replacement data provider duly chosen and appointed by the Investment Manager) to monitor GHG intensity and the revenue threshold requirements.

There are limitations regarding both methodologies and data. For some exposures, sustainability data is unavailable due to the lack of publicly disclosed information. Disclosure of ESG data is improving year-on-year with more companies publicly disclosing data to support the assessment of the environmental or social characteristics promoted by financial products.

Due diligence on underlying assets is carried out by reference to sustainability data and engagement.

A reference benchmark has not been designated for the purposes of assessing the environmental or social characteristics promoted by the Fund or the Master Fund.

No sustainable investment objective

The Fund promotes environmental or social characteristics but does not have sustainable investment as its objective.

Environmental or social characteristics of the financial product

The Fund is a feeder fund of the MetLife Sterling Investment Grade Corporate Debt Fund (the “Master Fund”). The information provided here is aligned to the information provided by the Master Fund.

The environmental and social characteristics promoted by the Master Fund are: (1) a reduction in GHG emissions; and (2) a reduction in the use of controversial weapons. As the Fund will invest at least 85% of its assets in the Master Fund, the environmental and social characteristics promoted by the Fund, are also: (1) a reduction in GHG emissions; and (2) a reduction in the use of controversial weapons.

Investment strategy

The investment objective of the Fund is to seek to achieve long-term capital growth and income. There is no assurance that such objective will be achieved.

In order to achieve the investment objective of the Fund, the Fund will invest at least 85% of its assets in the Master Fund and up to 15% in financial derivative instruments (“FDIs”). The Master Fund will seek to achieve its objective by investing primarily in a diversified portfolio of investment grade corporate debt securities either denominated in Sterling or hedged back to Sterling.

The Investment Manager believes fixed income markets are efficient with respect to interest rate risk, but regularly misprice securities that are exposed to credit, downgrade, and liquidity risks. The Investment Manager, through investing in the Master Fund, seeks to exploit inefficiencies in the market and provide investors with excess returns to the Master Fund reference index through (i) conducting proprietary, in-depth fundamental research (free cash flow and balance sheet analysis), (ii) analysing capital structures and covenants, (iii) reviewing of management and industry trends, (iv) targeting duration-neutral portfolios and (v) constructing portfolios with attractive risk / reward characteristics.

Further, the Investment Manager employs a carbon constraint and seeks to avoid investments associated with negative externalities through the consideration of PAIs and the application of exclusionary screens.

This strategy is implemented on a continuous basis through the ongoing consideration of the carbon constraint, the PAIs and the application of exclusionary screens, in addition to the requirements for the Investment Manager to manage the portfolio in accordance with the terms of the Supplement.

Proportion of investments

The minimum proportion of the investments used to meet the environmental and social characteristics promoted by the Master Fund in accordance with the binding elements of the investment strategy will be 75%, with it being noted that the Master Fund has not committed to making sustainable investments in accordance with Article 2(17) of SFDR. Accordingly, noting that the Fund will invest at least 85% of its assets in the Master Fund, the minimum proportion of investments of the Fund used to meet the environmental and social characteristics promoted by the Fund will be 60% (which is approximately 85% of 75%).

The purpose of the remaining proportion of the investments within the ‘Other’ category is (a) to adjust the interest rate risk of the Fund’s performance to a duration of approximately 5 years and (b) for liquidity and cash management purposes and no minimum environmental or social safeguards will be applied to these investments.

Monitoring of environmental or social characteristics

The binding elements of the Fund’s investment strategy used to select the investments to attain the promoted characteristics is that it will invest at least 85% of its assets in the Master Fund. The binding elements of the Master Fund’s investment strategy used to select the investments to attain the promoted characteristics are:

  1. the employment of a carbon constraint of keeping weighted average carbon intensity (WACI) (carbon intensity being Scope 1 & 2 emissions divided by sales reported by the investee companies) of the Master Fund below that of the Master Fund reference index.
  2. the employment of an exclusion screen in respect of companies exceeding the following revenue thresholds for specified activities:

    Activity Revenue threshold
    Thermal coal extraction >5%
    Thermal power generation >5%
    Oil and gas production >5%
  3. the employment of an exclusion screen in respect of companies that are involved in the production, sale and/or distribution of nuclear or other controversial weapons (including landmines, cluster weapons, depleted uranium, white phosphorous, incendiary weapons and biological/chemical weapons); and
  4. the consideration of the following PAIs:
    • GHG intensity of investee companies;
    • 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).

      The Investment Manager will also consider voluntary PAIs that are deemed applicable based on the relevant issuer and/or sector in which the issuer operates, and where data is readily available.

Methodologies

In order to measure the Fund’s and the Master Fund’s promotion of “a reduction in carbon emissions”, the Master Fund:

  1. employs a carbon constraint of keeping weighted average carbon intensity (WACI) (carbon intensity being Scope 1 & 2 emissions divided by sales reported by the investee companies) of the Master Fund below that of the Master Fund reference index.

    Scope 1 carbon emissions are those from sources owned or controlled by the investee company, typically direct combustion of fuel as in a furnace or vehicle. Scope 2 carbon emissions are those caused by the generation of electricity purchased by the investee company. Absolute carbon emissions are the total emissions of all investee companies, unadjusted for company size or the size of the investment. Carbon intensity is given by absolute carbon emissions divided by some measure of company size, in this case revenue. A portfolio’s WACI is achieved by calculating the carbon intensity (Scope 1 + 2 Emissions / GBPM Revenue) for each portfolio company and calculating the weighted average by portfolio weight. The Investment Manager believes that the way in which it calculates the WACI of both the Master Fund and the Master Fund reference index (i.e., by reference to the total value of sales of each underlying investee company, thereby adjusting for company size), is a more accurate measurement of carbon output, rather than simply measuring carbon output and/or intensity without taking account of the size of the investment. The figure for the WACI of the Master Fund is compared against the figure for the WACI of the Master Fund reference index and this comparison is monitored by the Investment Manager to ensure the figure for the Master Fund remains below that of the Master Fund reference index. If the Investment Manager determines that the Fund is not meeting the WACI requirement based on the data available to it, the Investment Manager will take steps to rebalance the Master Fund's portfolio to meet the WACI requirement, having regard to the overall environmental and social characteristics promoted by the Master Fund. Reporting on the Master Fund’s WACI relative to the Master Fund reference index can be provided by the Investment Manager upon request; and
  2. employs an exclusion screen in respect of companies exceeding the following revenue thresholds for specified activities:

    Activity Revenue threshold
    Thermal coal extraction >5%
    Thermal power generation >5%
    Oil and gas production >5%

In addition, and unrelated to the promoted characteristics of the Master Fund, the Master Fund excludes from its investment universe companies that generate for more than 5% of their revenue from tobacco production, and companies in violation with the UN Global Compact principles.

In order to measure the Master Fund’s promotion of “a reduction in the use of controversial weapons”, the Master Fund employs an exclusion screen in respect of companies that are involved in the production, sale and/or distribution of nuclear or other controversial weapons (including landmines, cluster weapons, depleted uranium, white phosphorous, incendiary weapons and biological/chemical weapons).

In addition, the Investment Manager considers the following PAIs on the Master Fund:

  • GHG intensity of investee companies;
  • violations of UN Global Compact principles and Organisation for Economic Cooperation and Development (OECD) Guidelines for Multinational Enterprise; and
  • exposure to controversial weapons (anti-personnel mines, cluster munitions, chemical weapons and biological weapons).

The Investment Manager will also consider voluntary PAIs that are deemed applicable based on the relevant issuer and/or sector in which the issuer operates, and where data is readily available.

Accordingly, in order to measure the attainment of the promoted characteristics, the Master Fund will determine whether the WACI of the Master Fund is below that of the Master Fund reference index, whether the Master Fund has employed the above referenced exclusionary screens and whether the Master Fund has considered the above referenced PAIs.

As the Fund will invest at least 85% of its assets in the Master Fund, the sustainability indicators that are used to measure the attainment of each of the environmental and social characteristics promoted by the Master Fund, are the same sustainability indicators that are used to measure the attainment of the environmental and social characteristics promoted by the Fund.

Engagement
The Investment Manager's approach to engagement is detailed in the MetLife Investment Management Stewardship Policy (which is available on request). Where possible and deemed necessary, analysts engage in ongoing dialogue with senior leadership of issuers to assess their business model resilience and responsiveness to the environmental, social, and governance factors impacting their business. As engagement is a dynamic process, the Investment Manager reserves the right to adapt its engagement strategy at any time.

Data sources and processing

Data sources used
The Investment Manager will rely on data from MSCI (or a replacement data provider duly chosen and appointed by the Investment Manager) to monitor GHG intensity and the revenue threshold requirements.

Measures taken to ensure data quality
The Investment Manager takes due care in selecting sustainability data providers as well as underlying sustainability research models and datapoints to anticipate and, where possible, mitigate limitations in the sustainability data quality and availability.

Should the Investment Manager determine that data provided to it by MSCI (or such replacement data provider) is incomplete or incorrect, the Investment Manager may use other sources available to it which it reasonably believes to be accurate.

How data is processed
The data referred to above is fed into the Investment Manager’s trading system as pre-trade rules to prevent the Master Fund from trading in the securities of excluded issuers.

Data is processed in accordance with applicable local laws on processing of data and in accordance with the Investment Manager's policies on data processing.

Proportion of data that is estimated
The Investment Manager only uses data as provided from the relevant sources in selecting relevant investments and in applying exclusion criteria. In some cases, the data provided by relevant sources may be estimated and the Investment Manager may also estimate data based on relevant methodologies.

Limitations to methodologies and data

There are limitations regarding both methodologies and data. For some issuers sustainability data is limited and/or unavailable due to the lack of publicly disclosed information. Disclosure of sustainability data is improving year-on-year with more issuers publicly disclosing data to support the assessment of the environmental or social characteristics promoted by financial products.

The data used is provided by external data providers and may contain inaccurate or incomplete data. In case of insufficient data, these data providers may rely on estimates and approximations using internal methodologies that may be subjective. These methodologies may also vary for each data provider. Differences in methodologies may also persist among issuer-reported data.

As the Investment Manager’s process relies on this data when making investment decisions, the data limitations noted above will in turn limit the process and may have an impact on our ability to measure whether the promoted characteristics are met and/or negative consequences for the Master Fund.

However, these challenges may be mitigated by issuer engagement and the Investment Manager does not expect these constraints to have a material impact on its ability to achieve the environmental or social characteristics promoted by the Master Fund.

SFDR seeks to achieve more transparency on how financial market participants integrate sustainability risks into their investment decisions and consideration of adverse sustainability impacts in the investment process. Data constraint is one of the biggest challenges when it comes to providing sustainability related information to end-investors, especially in the case of principal adverse impacts of investment decisions. There are also limitations on sustainability and ESG-related data provided by market participants on comparability.

Due diligence

Due diligence on underlying assets is carried out by reference to:

Sustainability Data
The Investment Manager will use the MSCI data to monitor GHG intensity and the revenue threshold requirements. All sustainability data is dependent on MSCI coverage of the assets of the Fund and the Master Fund.

The Investment Manager will use this MSCI data to ensure it meets the binding environmental or social characteristics promoted by the Fund and the Master Fund.

Engagement
Where possible and deemed necessary, analysts engage in ongoing dialogue with senior leadership of issuers to assess their business model resilience and responsiveness to the environmental, social, and governance risk factors impacting their business.

Engagement policies

Engagement is a core part of the investment process in terms of due diligence and ongoing monitoring.

The Investment Manager intends to engage with issuers to understand their sustainability strategy, obtain better data and facilitate the Fund and Master Fund’s sustainability commitments and reporting.

Should a controversy and/or reason to be concerned about the investment’s alignment to the environmental and/or social characteristics arise, an engagement plan will be compiled to monitor and remediate, where practicable.

Designated reference benchmark

No specific index has been designated as a reference benchmark for the purpose of attaining the environmental and/or social characteristics promoted by the Fund or the Master Fund.

FURTHER INFORMATION

This SRD is issued for information purposes only in accordance with the requirements of SFDR. It is not intended as investment advice and is not an offer or a recommendation about managing or investing assets.

The information contained herein is current as of the date of issuance and is subject to change without notice.

Past performance is not a guarantee or a reliable indicator of future results and an investment could lose value. All investments involve risk, including the possible loss of capital.

The Manager's registered office at 20-on-Hatch, Hatch Street Lower, Dublin 2, Ireland.

The Manager is authorised in Ireland and regulated by the Central Bank.

Sustainability-related disclosures

This sustainability-related disclosure ("SRD") is accurate as at: 24 March 2026

This SRD is issued by MetLife Investment Management Europe Limited (the "Manager") and contains information relating specifically to MetLife Sterling Investment Grade Corporate Debt 10 Year Feeder Fund (the “Fund”), an open-ended sub-fund of MetLife Investment Management RIAIF ICAV (the “ICAV”), an umbrella Irish collective asset-management vehicle with segregated liability between sub-funds governed by the laws of Ireland and authorised as a retail investor alternative investment fund under the Alternative Investment Fund Managers Directive 2011, as amended (the "AIFMD") by the Central Bank of Ireland (the "Central Bank"). MetLife Investment Management LLC serves as the investment manager to the Fund (the “Investment Manager”).

Pursuant to the Sustainable Finance Disclosure Regulation (Regulation EU/2019/2088) as amended ("SFDR"), the Fund discloses pursuant to Article 8 of SFDR as a financial product which promotes, among other characteristics, environmental or social characteristics, or a combination of those characteristics, provided that the companies in which the investments are made follow good governance practices.

This SRD has been prepared for the purpose of meeting the website disclosure requirements under Article 10 of SFDR relating to the Fund.

For further details on the Fund and the ICAV, please refer to currently issued version of the ICAV's Prospectus, the Supplement in respect of the Fund and the latest annual report which may be obtained free of charge on request.

Summary

The Fund promotes environmental and social characteristics but does not have sustainable investment as its objective.

The Fund is a feeder fund of the MetLife Sterling Investment Grade Corporate Debt Fund (the “Master Fund”). The information provided here is aligned to the information provided by the Master Fund.

The environmental and social characteristics promoted by the Master Fund are: (1) a reduction in GHG emissions; and (2) a reduction in the use of controversial weapons. As the Fund will invest at least 85% of its assets in the Master Fund, the environmental and social characteristics promoted by the Fund, are also: (1) a reduction in GHG emissions; and (2) a reduction in the use of controversial weapons.

The investment objective of the Fund is to seek to achieve long-term capital growth and income. In order to achieve the investment objective of the Fund, the Fund will invest at least 85% of its assets in the Master Fund and up to 15% in financial derivative instruments (“FDIs”). The Master Fund will seek to achieve its objective by investing primarily in a diversified portfolio of investment grade corporate debt securities either denominated in Sterling or hedged back to Sterling.

The minimum proportion of the investments used to meet the environmental and social characteristics promoted by the Master Fund in accordance with the binding elements of the investment strategy will be 75%, with it being noted that the Master Fund has not committed to making sustainable investments in accordance with Article 2(17) of SFDR. Accordingly, noting that the Fund will invest at least 85% of its assets in the Master Fund, the minimum proportion of investments of the Fund used to meet the environmental and social characteristics promoted by the Fund will be 60% (which is approximately 85% of 75%).

The binding elements of the Fund’s investment strategy used to select the investments to attain the promoted characteristics is that it will invest at least 85% of its assets in the Master Fund. The binding elements of the Master Fund’s investment strategy used to select the investments to attain the promoted characteristics are:

  1. the employment of a carbon constraint of keeping the weighted average carbon intensity (WACI) (carbon intensity being Scope 1 & 2 emissions divided by sales reported by the investee companies) of the Master Fund below that of the Master Fund reference index.
  2. the employment of an exclusion screen in respect of companies exceeding 5% revenue thresholds for any of the following activities: thermal coal extraction; thermal power generation; and oil and gas production.
  3. the employment of an exclusion screen in respect of companies that are involved in the production, sale and/or distribution of nuclear or other controversial weapons (including landmines, cluster weapons, depleted uranium, white phosphorous, incendiary weapons and biological/chemical weapons); and
  4. the consideration of the following PAIs:
    • GHG intensity of investee companies;
    • 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).

The Investment Manager will also consider voluntary PAIs that are deemed applicable based on the relevant issuer and/or sector in which the issuer operates, and where data is readily available.

The Investment Manager will rely on data from MSCI (or a replacement data provider duly chosen and appointed by the Investment Manager) to monitor GHG intensity and the revenue threshold requirements.

There are limitations regarding both methodologies and data. For some exposures, sustainability data is unavailable due to the lack of publicly disclosed information. Disclosure of ESG data is improving year-on-year with more companies publicly disclosing data to support the assessment of the environmental or social characteristics promoted by financial products.

Due diligence on underlying assets is carried out by reference to sustainability data and engagement.

A reference benchmark has not been designated for the purposes of assessing the environmental or social characteristics promoted by the Fund or the Master Fund.

No sustainable investment objective

The Fund promotes environmental or social characteristics but does not have sustainable investment as its objective.

Environmental or social characteristics of the financial product

The Fund is a feeder fund of the MetLife Sterling Investment Grade Corporate Debt Fund (the “Master Fund”). The information provided here is aligned to the information provided by the Master Fund.

The environmental and social characteristics promoted by the Master Fund are: (1) a reduction in GHG emissions; and (2) a reduction in the use of controversial weapons. As the Fund will invest at least 85% of its assets in the Master Fund, the environmental and social characteristics promoted by the Fund, are also: (1) a reduction in GHG emissions; and (2) a reduction in the use of controversial weapons.

Investment strategy

The investment objective of the Fund is to seek to achieve long-term capital growth and income. There is no assurance that such objective will be achieved.

In order to achieve the investment objective of the Fund, the Fund will invest at least 85% of its assets in the Master Fund and up to 15% in financial derivative instruments (“FDIs”). The Master Fund will seek to achieve its objective by investing primarily in a diversified portfolio of investment grade corporate debt securities either denominated in Sterling or hedged back to Sterling.

The Investment Manager believes fixed income markets are efficient with respect to interest rate risk, but regularly misprice securities that are exposed to credit, downgrade, and liquidity risks. The Investment Manager, through investing in the Master Fund, seeks to exploit inefficiencies in the market and provide investors with excess returns to the Master Fund reference index through (i) conducting proprietary, in-depth fundamental research (free cash flow and balance sheet analysis), (ii) analysing capital structures and covenants, (iii) reviewing of management and industry trends, (iv) targeting duration-neutral portfolios and (v) constructing portfolios with attractive risk / reward characteristics.

Further, the Investment Manager employs a carbon constraint and seeks to avoid investments associated with negative externalities through the consideration of PAIs and the application of exclusionary screens.

This strategy is implemented on a continuous basis through the ongoing consideration of the carbon constraint, the PAIs and the application of exclusionary screens, in addition to the requirements for the Investment Manager to manage the portfolio in accordance with the terms of the Supplement.

Proportion of investments

The minimum proportion of the investments used to meet the environmental and social characteristics promoted by the Master Fund in accordance with the binding elements of the investment strategy will be 75%, with it being noted that the Master Fund has not committed to making sustainable investments in accordance with Article 2(17) of SFDR. Accordingly, noting that the Fund will invest at least 85% of its assets in the Master Fund, the minimum proportion of investments of the Fund used to meet the environmental and social characteristics promoted by the Fund will be 60% (which is approximately 85% of 75%).

The purpose of the remaining proportion of the investments within the ‘Other’ category is (a) to adjust the interest rate risk of the Fund’s performance to a duration of approximately 10 years and (b) for liquidity and cash management purposes and no minimum environmental or social safeguards will be applied to these investments.

Monitoring of environmental or social characteristics

The binding elements of the Fund’s investment strategy used to select the investments to attain the promoted characteristics is that it will invest at least 85% of its assets in the Master Fund. The binding elements of the Master Fund’s investment strategy used to select the investments to attain the promoted characteristics are:

  1. the employment of a carbon constraint of keeping weighted average carbon intensity (WACI) (carbon intensity being Scope 1 & 2 emissions divided by sales reported by the investee companies) of the Master Fund below that of the Master Fund reference index.
  2. the employment of an exclusion screen in respect of companies exceeding the following revenue thresholds for specified activities:

    Activity Revenue threshold
    Thermal coal extraction >5%
    Thermal power generation >5%
    Oil and gas production >5%
  3. the employment of an exclusion screen in respect of companies that are involved in the production, sale and/or distribution of nuclear or other controversial weapons (including landmines, cluster weapons, depleted uranium, white phosphorous, incendiary weapons and biological/chemical weapons); and
  4. the consideration of the following PAIs:
    • GHG intensity of investee companies;
    • 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).

    The Investment Manager will also consider voluntary PAIs that are deemed applicable based on the relevant issuer and/or sector in which the issuer operates, and where data is readily available.

Methodologies

In order to measure the Fund’s and the Master Fund’s promotion of “a reduction in carbon emissions”, the Master Fund:

  1. employs a carbon constraint of keeping weighted average carbon intensity (WACI) (carbon intensity being Scope 1 & 2 emissions divided by sales reported by the investee companies) of the Master Fund below that of the Master Fund reference index.

    Scope 1 carbon emissions are those from sources owned or controlled by the investee company, typically direct combustion of fuel as in a furnace or vehicle. Scope 2 carbon emissions are those caused by the generation of electricity purchased by the investee company. Absolute carbon emissions are the total emissions of all investee companies, unadjusted for company size or the size of the investment. Carbon intensity is given by absolute carbon emissions divided by some measure of company size, in this case revenue. A portfolio’s WACI is achieved by calculating the carbon intensity (Scope 1 + 2 Emissions / GBPM Revenue) for each portfolio company and calculating the weighted average by portfolio weight. The Investment Manager believes that the way in which it calculates the WACI of both the Master Fund and the Master Fund reference index (i.e., by reference to the total value of sales of each underlying investee company, thereby adjusting for company size), is a more accurate measurement of carbon output, rather than simply measuring carbon output and/or intensity without taking account of the size of the investment. The figure for the WACI of the Master Fund is compared against the figure for the WACI of the Master Fund reference index and this comparison is monitored by the Investment Manager to ensure the figure for the Master Fund remains below that of the Master Fund reference index. If the Investment Manager determines that the Fund is not meeting the WACI requirement based on the data available to it, the Investment Manager will take steps to rebalance the Master Fund's portfolio to meet the WACI requirement, having regard to the overall environmental and social characteristics promoted by the Master Fund. Reporting on the Master Fund’s WACI relative to the Master Fund reference index can be provided by the Investment Manager upon request; and
  2. employs an exclusion screen in respect of companies exceeding the following revenue thresholds for specified activities:

    Activity Revenue threshold
    Thermal coal extraction >5%
    Thermal power generation >5%
    Oil and gas production >5%

In addition, and unrelated to the promoted characteristics of the Master Fund, the Master Fund excludes from its investment universe companies that generate for more than 5% of their revenue from tobacco production, and companies in violation with the UN Global Compact principles.

In order to measure the Master Fund’s promotion of “a reduction in the use of controversial weapons”, the Master Fund employs an exclusion screen in respect of companies that are involved in the production, sale and/or distribution of nuclear or other controversial weapons (including landmines, cluster weapons, depleted uranium, white phosphorous, incendiary weapons and biological/chemical weapons).

In addition, the Investment Manager considers the following PAIs on the Master Fund:

  • GHG intensity of investee companies;
  • violations of UN Global Compact principles and Organisation for Economic Cooperation and Development (OECD) Guidelines for Multinational Enterprise; and
  • exposure to controversial weapons (anti-personnel mines, cluster munitions, chemical weapons and biological weapons).

The Investment Manager will also consider voluntary PAIs that are deemed applicable based on the relevant issuer and/or sector in which the issuer operates, and where data is readily available.

Accordingly, in order to measure the attainment of the promoted characteristics, the Master Fund will determine whether the WACI of the Master Fund is below that of the Master Fund reference index, whether the Master Fund has employed the above referenced exclusionary screens and whether the Master Fund has considered the above referenced PAIs.

As the Fund will invest at least 85% of its assets in the Master Fund, the sustainability indicators that are used to measure the attainment of each of the environmental and social characteristics promoted by the Master Fund, are the same sustainability indicators that are used to measure the attainment of the environmental and social characteristics promoted by the Fund.

Engagement
The Investment Manager's approach to engagement is detailed in the MetLife Investment Management Stewardship Policy (which is available on request). Where possible and deemed necessary, analysts engage in ongoing dialogue with senior leadership of issuers to assess their business model resilience and responsiveness to the environmental, social, and governance factors impacting their business. As engagement is a dynamic process, the Investment Manager reserves the right to adapt its engagement strategy at any time.

Data sources and processing

Data sources used
The Investment Manager will rely on data from MSCI (or a replacement data provider duly chosen and appointed by the Investment Manager) to monitor GHG intensity and the revenue threshold requirements.

Measures taken to ensure data quality
The Investment Manager takes due care in selecting sustainability data providers as well as underlying sustainability research models and datapoints to anticipate and, where possible, mitigate limitations in the sustainability data quality and availability.

Should the Investment Manager determine that data provided to it by MSCI (or such replacement data provider) is incomplete or incorrect, the Investment Manager may use other sources available to it which it reasonably believes to be accurate.

How data is processed
The data referred to above is fed into the Investment Manager’s trading system as pre-trade rules to prevent the Master Fund from trading in the securities of excluded issuers.

Data is processed in accordance with applicable local laws on processing of data and in accordance with the Investment Manager's policies on data processing.

Proportion of data that is estimated
The Investment Manager only uses data as provided from the relevant sources in selecting relevant investments and in applying exclusion criteria. In some cases, the data provided by relevant sources may be estimated and the Investment Manager may also estimate data based on relevant methodologies.

Limitations to methodologies and data

There are limitations regarding both methodologies and data. For some issuers sustainability data is limited and/or unavailable due to the lack of publicly disclosed information. Disclosure of sustainability data is improving year-on-year with more issuers publicly disclosing data to support the assessment of the environmental or social characteristics promoted by financial products.

The data used is provided by external data providers and may contain inaccurate or incomplete data. In case of insufficient data, these data providers may rely on estimates and approximations using internal methodologies that may be subjective. These methodologies may also vary for each data provider. Differences in methodologies may also persist among issuer-reported data.

As the Investment Manager’s process relies on this data when making investment decisions, the data limitations noted above will in turn limit the process and may have an impact on our ability to measure whether the promoted characteristics are met and/or negative consequences for the Master Fund.

However, these challenges may be mitigated by issuer engagement and the Investment Manager does not expect these constraints to have a material impact on its ability to achieve the environmental or social characteristics promoted by the Master Fund.

SFDR seeks to achieve more transparency on how financial market participants integrate sustainability risks into their investment decisions and consideration of adverse sustainability impacts in the investment process. Data constraint is one of the biggest challenges when it comes to providing sustainability related information to end-investors, especially in the case of principal adverse impacts of investment decisions. There are also limitations on sustainability and ESG-related data provided by market participants on comparability.

Due diligence

Due diligence on underlying assets is carried out by reference to:

Sustainability Data
The Investment Manager will use the MSCI data to monitor GHG intensity and the revenue threshold requirements. All sustainability data is dependent on MSCI coverage of the assets of the Fund and the Master Fund.

The Investment Manager will use this MSCI data to ensure it meets the binding environmental or social characteristics promoted by the Fund and the Master Fund.

Engagement
Where possible and deemed necessary, analysts engage in ongoing dialogue with senior leadership of issuers to assess their business model resilience and responsiveness to the environmental, social, and governance risk factors impacting their business.

Engagement policies

Engagement is a core part of the investment process in terms of due diligence and ongoing monitoring.

The Investment Manager intends to engage with issuers to understand their sustainability strategy, obtain better data and facilitate the Fund and Master Fund’s sustainability commitments and reporting.

Should a controversy and/or reason to be concerned about the investment’s alignment to the environmental and/or social characteristics arise, an engagement plan will be compiled to monitor and remediate, where practicable.

Designated reference benchmark

No specific index has been designated as a reference benchmark for the purpose of attaining the environmental and/or social characteristics promoted by the Fund or the Master Fund.

FURTHER INFORMATION

This SRD is issued for information purposes only in accordance with the requirements of SFDR. It is not intended as investment advice and is not an offer or a recommendation about managing or investing assets.

The information contained herein is current as of the date of issuance and is subject to change without notice.

Past performance is not a guarantee or a reliable indicator of future results and an investment could lose value. All investments involve risk, including the possible loss of capital.

The Manager's registered office at 20-on-Hatch, Hatch Street Lower, Dublin 2, Ireland.

The Manager is authorised in Ireland and regulated by the Central Bank.

Sustainability-related disclosures

This sustainability-related disclosure ("SRD") is accurate as at: 24 March 2026

This SRD is issued by MetLife Investment Management Europe Limited (the "Manager") and contains information relating specifically to MetLife Sterling Investment Grade Corporate Debt 16 Year Feeder Fund (the “Fund”), an open-ended sub-fund of MetLife Investment Management RIAIF ICAV (the “ICAV”), an umbrella Irish collective asset-management vehicle with segregated liability between sub-funds governed by the laws of Ireland and authorised as a retail investor alternative investment fund under the Alternative Investment Fund Managers Directive 2011, as amended (the "AIFMD") by the Central Bank of Ireland (the "Central Bank"). MetLife Investment Management LLC serves as the investment manager to the Fund (the “Investment Manager”).

Pursuant to the Sustainable Finance Disclosure Regulation (Regulation EU/2019/2088) as amended ("SFDR"), the Fund discloses pursuant to Article 8 of SFDR as a financial product which promotes, among other characteristics, environmental or social characteristics, or a combination of those characteristics, provided that the companies in which the investments are made follow good governance practices.

This SRD has been prepared for the purpose of meeting the website disclosure requirements under Article 10 of SFDR relating to the Fund.

For further details on the Fund and the ICAV, please refer to currently issued version of the ICAV's Prospectus, the Supplement in respect of the Fund and the latest annual report which may be obtained free of charge on request.

Summary

The Fund promotes environmental and social characteristics but does not have sustainable investment as its objective.

The Fund is a feeder fund of the MetLife Sterling Investment Grade Corporate Debt Fund (the “Master Fund”). The information provided here is aligned to the information provided by the Master Fund.

The environmental and social characteristics promoted by the Master Fund are: (1) a reduction in GHG emissions; and (2) a reduction in the use of controversial weapons. As the Fund will invest at least 85% of its assets in the Master Fund, the environmental and social characteristics promoted by the Fund, are also: (1) a reduction in GHG emissions; and (2) a reduction in the use of controversial weapons.

The investment objective of the Fund is to seek to achieve long-term capital growth and income. In order to achieve the investment objective of the Fund, the Fund will invest at least 85% of its assets in the Master Fund and up to 15% in financial derivative instruments (“FDIs”). The Master Fund will seek to achieve its objective by investing primarily in a diversified portfolio of investment grade corporate debt securities either denominated in Sterling or hedged back to Sterling.

The minimum proportion of the investments used to meet the environmental and social characteristics promoted by the Master Fund in accordance with the binding elements of the investment strategy will be 75%, with it being noted that the Master Fund has not committed to making sustainable investments in accordance with Article 2(17) of SFDR. Accordingly, noting that the Fund will invest at least 85% of its assets in the Master Fund, the minimum proportion of investments of the Fund used to meet the environmental and social characteristics promoted by the Fund will be 60% (which is approximately 85% of 75%).

The binding elements of the Fund’s investment strategy used to select the investments to attain the promoted characteristics is that it will invest at least 85% of its assets in the Master Fund. The binding elements of the Master Fund’s investment strategy used to select the investments to attain the promoted characteristics are:

  1. the employment of a carbon constraint of keeping the weighted average carbon intensity (WACI) (carbon intensity being Scope 1 & 2 emissions divided by sales reported by the investee companies) of the Master Fund below that of the Master Fund reference index.
  2. the employment of an exclusion screen in respect of companies exceeding 5% revenue thresholds for any of the following activities: thermal coal extraction; thermal power generation; and oil and gas production.
  3. the employment of an exclusion screen in respect of companies that are involved in the production, sale and/or distribution of nuclear or other controversial weapons (including landmines, cluster weapons, depleted uranium, white phosphorous, incendiary weapons and biological/chemical weapons); and
  4. the consideration of the following PAIs:
    • GHG intensity of investee companies;
    • 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).

The Investment Manager will also consider voluntary PAIs that are deemed applicable based on the relevant issuer and/or sector in which the issuer operates, and where data is readily available.

The Investment Manager will rely on data from MSCI (or a replacement data provider duly chosen and appointed by the Investment Manager) to monitor GHG intensity and the revenue threshold requirements.

There are limitations regarding both methodologies and data. For some exposures, sustainability data is unavailable due to the lack of publicly disclosed information. Disclosure of ESG data is improving year-on-year with more companies publicly disclosing data to support the assessment of the environmental or social characteristics promoted by financial products.

Due diligence on underlying assets is carried out by reference to sustainability data and engagement.

A reference benchmark has not been designated for the purposes of assessing the environmental or social characteristics promoted by the Fund or the Master Fund.

No sustainable investment objective

The Fund promotes environmental or social characteristics but does not have sustainable investment as its objective.

Environmental or social characteristics of the financial product

The Fund is a feeder fund of the MetLife Sterling Investment Grade Corporate Debt Fund (the “Master Fund”). The information provided here is aligned to the information provided by the Master Fund.

The environmental and social characteristics promoted by the Master Fund are: (1) a reduction in GHG emissions; and (2) a reduction in the use of controversial weapons. As the Fund will invest at least 85% of its assets in the Master Fund, the environmental and social characteristics promoted by the Fund, are also: (1) a reduction in GHG emissions; and (2) a reduction in the use of controversial weapons.

Investment strategy

The investment objective of the Fund is to seek to achieve long-term capital growth and income. There is no assurance that such objective will be achieved.

In order to achieve the investment objective of the Fund, the Fund will invest at least 85% of its assets in the Master Fund and up to 15% in financial derivative instruments (“FDIs”). The Master Fund will seek to achieve its objective by investing primarily in a diversified portfolio of investment grade corporate debt securities either denominated in Sterling or hedged back to Sterling.

The Investment Manager believes fixed income markets are efficient with respect to interest rate risk, but regularly misprice securities that are exposed to credit, downgrade, and liquidity risks. The Investment Manager, through investing in the Master Fund, seeks to exploit inefficiencies in the market and provide investors with excess returns to the Master Fund reference index through (i) conducting proprietary, in-depth fundamental research (free cash flow and balance sheet analysis), (ii) analysing capital structures and covenants, (iii) reviewing of management and industry trends, (iv) targeting duration-neutral portfolios and (v) constructing portfolios with attractive risk / reward characteristics.

Further, the Investment Manager employs a carbon constraint and seeks to avoid investments associated with negative externalities through the consideration of PAIs and the application of exclusionary screens.

This strategy is implemented on a continuous basis through the ongoing consideration of the carbon constraint, the PAIs and the application of exclusionary screens, in addition to the requirements for the Investment Manager to manage the portfolio in accordance with the terms of the Supplement.

Proportion of investments

The minimum proportion of the investments used to meet the environmental and social characteristics promoted by the Master Fund in accordance with the binding elements of the investment strategy will be 75%, with it being noted that the Master Fund has not committed to making sustainable investments in accordance with Article 2(17) of SFDR. Accordingly, noting that the Fund will invest at least 85% of its assets in the Master Fund, the minimum proportion of investments of the Fund used to meet the environmental and social characteristics promoted by the Fund will be 60% (which is approximately 85% of 75%).

The purpose of the remaining proportion of the investments within the ‘Other’ category is (a) to adjust the interest rate risk of the Fund’s performance to a duration of approximately 16 years and (b) for liquidity and cash management purposes and no minimum environmental or social safeguards will be applied to these investments.

Monitoring of environmental or social characteristics

The binding elements of the Fund’s investment strategy used to select the investments to attain the promoted characteristics is that it will invest at least 85% of its assets in the Master Fund. The binding elements of the Master Fund’s investment strategy used to select the investments to attain the promoted characteristics are:

  1. the employment of a carbon constraint of keeping weighted average carbon intensity (WACI) (carbon intensity being Scope 1 & 2 emissions divided by sales reported by the investee companies) of the Master Fund below that of the Master Fund reference index.
  2. the employment of an exclusion screen in respect of companies exceeding the following revenue thresholds for specified activities:

    Activity Revenue threshold
    Thermal coal extraction >5%
    Thermal power generation >5%
    Oil and gas production >5%

  3. the employment of an exclusion screen in respect of companies that are involved in the production, sale and/or distribution of nuclear or other controversial weapons (including landmines, cluster weapons, depleted uranium, white phosphorous, incendiary weapons and biological/chemical weapons); and
  4. the consideration of the following PAIs:
    • GHG intensity of investee companies;
    • 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).

The Investment Manager will also consider voluntary PAIs that are deemed applicable based on the relevant issuer and/or sector in which the issuer operates, and where data is readily available.

Methodologies

In order to measure the Fund’s and the Master Fund’s promotion of “a reduction in carbon emissions”, the Master Fund:

  1. employs a carbon constraint of keeping weighted average carbon intensity (WACI) (carbon intensity being Scope 1 & 2 emissions divided by sales reported by the investee companies) of the Master Fund below that of the Master Fund reference index.

    Scope 1 carbon emissions are those from sources owned or controlled by the investee company, typically direct combustion of fuel as in a furnace or vehicle. Scope 2 carbon emissions are those caused by the generation of electricity purchased by the investee company. Absolute carbon emissions are the total emissions of all investee companies, unadjusted for company size or the size of the investment. Carbon intensity is given by absolute carbon emissions divided by some measure of company size, in this case revenue. A portfolio’s WACI is achieved by calculating the carbon intensity (Scope 1 + 2 Emissions / GBPM Revenue) for each portfolio company and calculating the weighted average by portfolio weight. The Investment Manager believes that the way in which it calculates the WACI of both the Master Fund and the Master Fund reference index (i.e., by reference to the total value of sales of each underlying investee company, thereby adjusting for company size), is a more accurate measurement of carbon output, rather than simply measuring carbon output and/or intensity without taking account of the size of the investment. The figure for the WACI of the Master Fund is compared against the figure for the WACI of the Master Fund reference index and this comparison is monitored by the Investment Manager to ensure the figure for the Master Fund remains below that of the Master Fund reference index. If the Investment Manager determines that the Fund is not meeting the WACI requirement based on the data available to it, the Investment Manager will take steps to rebalance the Master Fund's portfolio to meet the WACI requirement, having regard to the overall environmental and social characteristics promoted by the Master Fund. Reporting on the Master Fund’s WACI relative to the Master Fund reference index can be provided by the Investment Manager upon request; and
  2. employs an exclusion screen in respect of companies exceeding the following revenue thresholds for specified activities:

    Activity Revenue threshold
    Thermal coal extraction >5%
    Thermal power generation >5%
    Oil and gas production >5%

In addition, and unrelated to the promoted characteristics of the Master Fund, the Master Fund excludes from its investment universe companies that generate for more than 5% of their revenue from tobacco production, and companies in violation with the UN Global Compact principles.

In order to measure the Master Fund’s promotion of “a reduction in the use of controversial weapons”, the Master Fund employs an exclusion screen in respect of companies that are involved in the production, sale and/or distribution of nuclear or other controversial weapons (including landmines, cluster weapons, depleted uranium, white phosphorous, incendiary weapons and biological/chemical weapons).

In addition, the Investment Manager considers the following PAIs on the Master Fund:

  • GHG intensity of investee companies;
  • violations of UN Global Compact principles and Organisation for Economic Cooperation and Development (OECD) Guidelines for Multinational Enterprise; and
  • exposure to controversial weapons (anti-personnel mines, cluster munitions, chemical weapons and biological weapons).

The Investment Manager will also consider voluntary PAIs that are deemed applicable based on the relevant issuer and/or sector in which the issuer operates, and where data is readily available.

Accordingly, in order to measure the attainment of the promoted characteristics, the Master Fund will determine whether the WACI of the Master Fund is below that of the Master Fund reference index, whether the Master Fund has employed the above referenced exclusionary screens and whether the Master Fund has considered the above referenced PAIs.

As the Fund will invest at least 85% of its assets in the Master Fund, the sustainability indicators that are used to measure the attainment of each of the environmental and social characteristics promoted by the Master Fund, are the same sustainability indicators that are used to measure the attainment of the environmental and social characteristics promoted by the Fund.

Engagement
The Investment Manager's approach to engagement is detailed in the MetLife Investment Management Stewardship Policy (which is available on request). Where possible and deemed necessary, analysts engage in ongoing dialogue with senior leadership of issuers to assess their business model resilience and responsiveness to the environmental, social, and governance factors impacting their business. As engagement is a dynamic process, the Investment Manager reserves the right to adapt its engagement strategy at any time.

Data sources and processing

Data sources used
The Investment Manager will rely on data from MSCI (or a replacement data provider duly chosen and appointed by the Investment Manager) to monitor GHG intensity and the revenue threshold requirements.

Measures taken to ensure data quality
The Investment Manager takes due care in selecting sustainability data providers as well as underlying sustainability research models and datapoints to anticipate and, where possible, mitigate limitations in the sustainability data quality and availability.

Should the Investment Manager determine that data provided to it by MSCI (or such replacement data provider) is incomplete or incorrect, the Investment Manager may use other sources available to it which it reasonably believes to be accurate.

How data is processed
The data referred to above is fed into the Investment Manager’s trading system as pre-trade rules to prevent the Master Fund from trading in the securities of excluded issuers.

Data is processed in accordance with applicable local laws on processing of data and in accordance with the Investment Manager's policies on data processing.

Proportion of data that is estimated
The Investment Manager only uses data as provided from the relevant sources in selecting relevant investments and in applying exclusion criteria. In some cases, the data provided by relevant sources may be estimated and the Investment Manager may also estimate data based on relevant methodologies.

Limitations to methodologies and data

There are limitations regarding both methodologies and data. For some issuers sustainability data is limited and/or unavailable due to the lack of publicly disclosed information. Disclosure of sustainability data is improving year-on-year with more issuers publicly disclosing data to support the assessment of the environmental or social characteristics promoted by financial products.

The data used is provided by external data providers and may contain inaccurate or incomplete data. In case of insufficient data, these data providers may rely on estimates and approximations using internal methodologies that may be subjective. These methodologies may also vary for each data provider. Differences in methodologies may also persist among issuer-reported data.

As the Investment Manager’s process relies on this data when making investment decisions, the data limitations noted above will in turn limit the process and may have an impact on our ability to measure whether the promoted characteristics are met and/or negative consequences for the Master Fund.

However, these challenges may be mitigated by issuer engagement and the Investment Manager does not expect these constraints to have a material impact on its ability to achieve the environmental or social characteristics promoted by the Master Fund.

SFDR seeks to achieve more transparency on how financial market participants integrate sustainability risks into their investment decisions and consideration of adverse sustainability impacts in the investment process. Data constraint is one of the biggest challenges when it comes to providing sustainability related information to end-investors, especially in the case of principal adverse impacts of investment decisions. There are also limitations on sustainability and ESG-related data provided by market participants on comparability.

Due diligence

Due diligence on underlying assets is carried out by reference to:

Sustainability Data
The Investment Manager will use the MSCI data to monitor GHG intensity and the revenue threshold requirements. All sustainability data is dependent on MSCI coverage of the assets of the Fund and the Master Fund.

The Investment Manager will use this MSCI data to ensure it meets the binding environmental or social characteristics promoted by the Fund and the Master Fund.

Engagement
Where possible and deemed necessary, analysts engage in ongoing dialogue with senior leadership of issuers to assess their business model resilience and responsiveness to the environmental, social, and governance risk factors impacting their business.

Engagement policies

Engagement is a core part of the investment process in terms of due diligence and ongoing monitoring.

The Investment Manager intends to engage with issuers to understand their sustainability strategy, obtain better data and facilitate the Fund and Master Fund’s sustainability commitments and reporting.

Should a controversy and/or reason to be concerned about the investment’s alignment to the environmental and/or social characteristics arise, an engagement plan will be compiled to monitor and remediate, where practicable.

Designated reference benchmark

No specific index has been designated as a reference benchmark for the purpose of attaining the environmental and/or social characteristics promoted by the Fund or the Master Fund.

FURTHER INFORMATION

This SRD is issued for information purposes only in accordance with the requirements of SFDR. It is not intended as investment advice and is not an offer or a recommendation about managing or investing assets.

The information contained herein is current as of the date of issuance and is subject to change without notice.

Past performance is not a guarantee or a reliable indicator of future results and an investment could lose value. All investments involve risk, including the possible loss of capital.

The Manager's registered office at 20-on-Hatch, Hatch Street Lower, Dublin 2, Ireland.

The Manager is authorised in Ireland and regulated by the Central Bank.

Sustainability-related disclosures

This sustainability-related disclosure ("SRD") is accurate as at: 27 August 2025

This SRD is issued by MetLife Investment Management Europe Limited (the "Manager") and contains information relating specifically to MetLife Feeder Fund 0 (the “Fund”), an open-ended sub-fund of MetLife Investment Management RIAIF ICAV (the “ICAV”), an umbrella Irish collective asset-management vehicle with segregated liability between sub-funds governed by the laws of Ireland and authorised as a retail investor alternative investment fund under the Alternative Investment Fund Managers Directive 2011, as amended (the "AIFMD") by the Central Bank of Ireland (the "Central Bank"). MetLife Investment Management LLC serves as the investment manager to the Fund (the “Investment Manager”).

Pursuant to the Sustainable Finance Disclosure Regulation (Regulation EU/2019/2088) as amended ("SFDR"), the Fund discloses pursuant to Article 8 of SFDR as a financial product which promotes, among other characteristics, environmental or social characteristics, or a combination of those characteristics, provided that the companies in which the investments are made follow good governance practices.

This SRD has been prepared for the purpose of meeting the website disclosure requirements under Article 10 of SFDR relating to the Fund.

For further details on the Fund and the ICAV, please refer to currently issued version of the ICAV's Prospectus, the Supplement in respect of the Fund and the latest annual report which may be obtained free of charge on request.

Summary
The Fund promotes environmental and social characteristics but does not have sustainable investment as its objective.

The Fund is a feeder fund of the MetLife Sterling Short-Term Fixed Income Fund (the “Master Fund”). The information provided here is aligned to the information provided by the Master Fund.

The environmental and social characteristics promoted by the Master Fund are: (1) a reduction in GHG emissions; and (2) a reduction in the production and distribution of controversial weapons. As the Fund will invest at least 85% of its assets in the Master Fund, the environmental and social characteristics promoted by the Fund, are also: (1) a reduction in GHG emissions; and (2) a reduction in the production and distribution of controversial weapons.

The investment strategy of the Fund is to invest at least 85% of its assets in the Master Fund and up to 15% in financial derivative instruments (“FDIs”). The investment objective of the Master Fund is the preservation of capital through investment in high quality assets. There is no assurance that such objective will be achieved. The Master Fund will seek to achieve its objective by investing primarily in a diversified portfolio of Investment Grade Fixed Income Securities either denominated in Sterling or hedged back to Sterling.

The minimum proportion of the investments of the Master Fund used to meet the environmental and social characteristics promoted by the Master Fund in accordance with the binding elements of the investment strategy will be 75%, with it being noted that the Master Fund has not committed to making sustainable investments in accordance with Article 2(17) of SFDR. Accordingly, noting that the Fund will invest at least 85% of its assets in the Master Fund, the minimum proportion of investments of the Fund used to meet the environmental and social characteristics promoted by the Fund will be 63.75% (which is 85% of 75%).

The binding element of the Fund’s investment strategy used to select the investments to attain the promoted characteristics is that it will invest at least 85% of its assets in the Master Fund. The binding elements of the Master Fund’s investment strategy used to select the investments to attain the promoted characteristics are:

  1. the employment of an exclusion screen in respect of companies exceeding revenue thresholds for thermal coal extraction, thermal power generation, and oil and gas production activities; and
  2. the employment of an exclusion screen in respect of companies that are involved in the production, sale and/or distribution of nuclear or other controversial weapons; and
  3. the consideration of the following PAIs:
    • 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).

The Investment Manager will also consider voluntary PAIs that are deemed applicable based on the relevant issuer and/or sector in which the issuer operates, and where data is readily available.

The Investment Manager will rely on data from MSCI (or a replacement data provider duly chosen and appointed by the Investment Manager) to monitor the revenue threshold requirements.

There are limitations regarding both methodologies and data. For some exposures, sustainability data is unavailable due to the lack of publicly disclosed information. Disclosure of ESG data is improving year-on-year with more companies publicly disclosing data to support the assessment of the environmental or social characteristics promoted by financial products.

Due diligence on underlying assets is carried out by reference to sustainability data and engagement.

A reference benchmark has not been designated for the purposes of assessing the environmental or social characteristics promoted by the Fund or the Master Fund.

No sustainable investment objective

The Fund promotes environmental or social characteristics but does not have sustainable investment as its objective.

Environmental or social characteristics of the financial product

The Fund is a feeder fund of the MetLife Sterling Short-Term Fixed Income Fund (the “Master Fund”). The information provided here is aligned to the information provided by the Master Fund.

The environmental and social characteristics promoted by the Master Fund are: (1) a reduction in GHG emissions; and (2) a reduction in the production and distribution of controversial weapons. As the Fund will invest at least 85% of its assets in the Master Fund, the environmental and social characteristics promoted by the Fund, are also: (1) a reduction in GHG emissions; and (2) a reduction in the production and distribution of controversial weapons.

Investment strategy

The investment strategy of the Fund is to invest at least 85% of its assets in the Master Fund and up to 15% in financial derivative instruments (“FDIs”). The investment objective of the Master Fund is the preservation of capital through investment in high quality assets. There is no assurance that such objective will be achieved. The Master Fund will seek to achieve its objective by investing primarily in a diversified portfolio of Investment Grade Fixed Income Securities either denominated in Sterling or hedged back to Sterling. The Investment Manager believes fixed income markets are efficient with respect to interest rate risk, but regularly misprice securities that are exposed to credit, downgrade, and liquidity risks. The Investment Manager seeks to exploit inefficiencies in the market and provide investors with excess returns to the Master Fund Reference Index through (i) conducting proprietary, in-depth fundamental research, (ii) analysing capital structures and covenants, (iii) reviewing of management and industry trends, (iv) targeting duration-neutral portfolios and (v) constructing portfolios with attractive risk / reward characteristics. The Investment Manager seeks to avoid investments associated with negative externalities through the consideration of PAIs and the application of exclusionary screens. This strategy is implemented on a continuous basis through the ongoing consideration of the PAIs and the application of exclusionary screens, in addition to the requirements for the Investment Manager to manage the portfolio in accordance with the terms of the Master Fund Supplement (including the SFDR Annex).

Proportion of investments

The minimum proportion of the investments of the Master Fund used to meet the environmental and social characteristics promoted by the Master Fund in accordance with the binding elements of the investment strategy will be 75%, with it being noted that the Master Fund has not committed to making sustainable investments in accordance with Article 2(17) of SFDR. Accordingly, noting that the Fund will invest at least 85% of its assets in the Master Fund, the minimum proportion of investments of the Fund used to meet the environmental and social characteristics promoted by the Fund will be 63.75% (which is 85% of 75%). The purpose of the remaining proportion of the investments within the ‘#2 Other’ category is (a) to adjust the equity and currency risk through the Fund’s use of FDIs and (b) for liquidity and cash management purposes. No minimum environmental or social safeguards are applied to these investments listed in (a) and (b). The remaining portion of the Fund’s “#2 Other” allocation (after (a) and (b) above) arises as a result of Master Fund’s “#2 Other” allocation – whilst the Fund is investing in the Master Fund for investment purposes, Master Fund’s “#2 Other” allocation will include CIS and money market instruments used by the Master Fund for liquidity and cash management purposes (with no minimum environmental or social safeguards being applied to these investments by the Master Fund).

Monitoring of environmental or social characteristics

The binding element of the Fund’s investment strategy used to select the investments to attain the promoted characteristics is that it will invest at least 85% of its assets in the Master Fund. The binding elements of the Master Fund’s investment strategy used to select the investments to attain the promoted characteristics are:

  1. the employment of an exclusion screen in respect of companies exceeding the following revenue thresholds for specified activities:

    Activity Revenue threshold
    Thermal coal extraction >5%
    Thermal power generation >5%
    Oil and gas production >5%
  2. the employment of an exclusion screen in respect of companies that are involved in the production, sale and/or distribution of nuclear or other controversial weapons; and
  3. the consideration of the following PAIs:
    • 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).

The Investment Manager will also consider voluntary PAIs that are deemed applicable based on the relevant issuer and/or sector in which the issuer operates, and where data is readily available.

Methodologies

In order to measure the Fund’s and the Master Fund’s promotion of “a reduction in carbon emissions”, the Master Fund:

  1. employs a carbon constraint of keeping weighted average carbon intensity (WACI) (carbon intensity being Scope 1 & 2 emissions divided by sales reported by the investee companies) of the Master Fund below that of the Master Fund reference index.

    Scope 1 carbon emissions are those from sources owned or controlled by the investee company, typically direct combustion of fuel as in a furnace or vehicle. Scope 2 carbon emissions are those caused by the generation of electricity purchased by the investee company. Absolute carbon emissions are the total emissions of all investee companies, unadjusted for company size or the size of the investment. Carbon intensity is given by absolute carbon emissions divided by some measure of company size, in this case revenue. A portfolio’s WACI is achieved by calculating the carbon intensity (Scope 1 + 2 Emissions / GBPM Revenue) for each portfolio company and calculating the weighted average by portfolio weight. The Investment Manager believes that the way in which it calculates the WACI of both the Master Fund and the Master Fund reference index (i.e., by reference to the total value of sales of each underlying investee company, thereby adjusting for company size), is a more accurate measurement of carbon output, rather than simply measuring carbon output and/or intensity without taking account of the size of the investment. The figure for the WACI of the Master Fund is compared against the figure for the WACI of the Master Fund reference index and this comparison is monitored by the Investment Manager to ensure the figure for the Master Fund remains below that of the Master Fund reference index. If the Investment Manager determines that the Fund is not meeting the WACI requirement based on the data available to it, the Investment Manager will take steps to rebalance the Master Fund's portfolio to meet the WACI requirement, having regard to the overall environmental and social characteristics promoted by the Master Fund. Reporting on the Master Fund’s WACI relative to the Master Fund reference index can be provided by the Investment Manager upon request; and
  2. employs an exclusion screen in respect of companies exceeding the following revenue thresholds for specified activities:

    Activity Revenue threshold
    Thermal coal extraction >5%
    Thermal power generation >5%
    Oil and gas production >5%

In addition, and unrelated to the promoted characteristics of the Master Fund, the Master Fund excludes from its investment universe companies that generate for more than 5% of their revenue from tobacco production, and companies in violation with the UN Global Compact principles.

In order to measure the Master Fund’s promotion of “a reduction in the use of controversial weapons”, the Master Fund employs an exclusion screen in respect of companies that are involved in the production, sale and/or distribution of nuclear or other controversial weapons (including landmines, cluster weapons, depleted uranium, white phosphorous, incendiary weapons and biological/chemical weapons).

In addition, the Investment Manager considers the following PAIs on the Master Fund:

  • GHG intensity of investee companies;
  • violations of UN Global Compact principles and Organisation for Economic Cooperation and Development (OECD) Guidelines for Multinational Enterprise; and
  • exposure to controversial weapons (anti-personnel mines, cluster munitions, chemical weapons and biological weapons).

The Investment Manager will also consider voluntary PAIs that are deemed applicable based on the relevant issuer and/or sector in which the issuer operates, and where data is readily available.

Accordingly, in order to measure the attainment of the promoted characteristics, the Master Fund will determine whether the WACI of the Master Fund is below that of the Master Fund reference index, whether the Master Fund has employed the above referenced exclusionary screens and whether the Master Fund has considered the above referenced PAIs.

As the Fund will invest at least 85% of its assets in the Master Fund, the sustainability indicators that are used to measure the attainment of each of the environmental and social characteristics promoted by the Master Fund, are the same sustainability indicators that are used to measure the attainment of the environmental and social characteristics promoted by the Fund.

Engagement
The Investment Manager's approach to engagement is detailed in the MetLife Investment Management Stewardship Policy (which is available on request). Where possible and deemed necessary, analysts engage in ongoing dialogue with senior leadership of issuers to assess their business model resilience and responsiveness to the environmental, social, and governance factors impacting their business. As engagement is a dynamic process, the Investment Manager reserves the right to adapt its engagement strategy at any time.

Data sources and processing

Data sources used

The Investment Manager will rely on data from MSCI (or a replacement data provider duly chosen and appointed by the Investment Manager) to monitor GHG intensity and the revenue threshold requirements.

Measures taken to ensure data quality

The Investment Manager takes due care in selecting sustainability data providers as well as underlying sustainability research models and datapoints to anticipate and, where possible, mitigate limitations in the sustainability data quality and availability.

Should the Investment Manager determine that data provided to it by MSCI (or such replacement data provider) is incomplete or incorrect, the Investment Manager may use other sources available to it which it reasonably believes to be accurate.

How data is processed

The data referred to above is fed into the Investment Manager’s trading system as pre-trade rules to prevent the Master Fund from trading in the securities of excluded issuers.

Data is processed in accordance with applicable local laws on processing of data and in accordance with the Investment Manager's policies on data processing.

Proportion of data that is estimated

The Investment Manager only uses data as provided from the relevant sources in selecting relevant investments and in applying exclusion criteria. In some cases, the data provided by relevant sources may be estimated and the Investment Manager may also estimate data based on relevant methodologies.

Limitations to methodologies and data

There are limitations regarding both methodologies and data. For some issuers sustainability data is limited and/or unavailable due to the lack of publicly disclosed information. Disclosure of sustainability data is improving year-on-year with more issuers publicly disclosing data to support the assessment of the environmental or social characteristics promoted by financial products.

The data used is provided by external data providers and may contain inaccurate or incomplete data. In case of insufficient data, these data providers may rely on estimates and approximations using internal methodologies that may be subjective. These methodologies may also vary for each data provider. Differences in methodologies may also persist among issuer-reported data.

As the Investment Manager’s process relies on this data when making investment decisions, the data limitations noted above will in turn limit the process and may have an impact on our ability to measure whether the promoted characteristics are met and/or negative consequences for the Master Fund.

However, these challenges may be mitigated by issuer engagement and the Investment Manager does not expect these constraints to have a material impact on its ability to achieve the environmental or social characteristics promoted by the Master Fund.

SFDR seeks to achieve more transparency on how financial market participants integrate sustainability risks into their investment decisions and consideration of adverse sustainability impacts in the investment process. Data constraint is one of the biggest challenges when it comes to providing sustainability related information to end-investors, especially in the case of principal adverse impacts of investment decisions. There are also limitations on sustainability and ESG-related data provided by market participants on comparability.

Due diligence

Due diligence on underlying assets is carried out by reference to:

Sustainability Data

The Investment Manager will use the MSCI data to monitor GHG intensity and the revenue threshold requirements. All sustainability data is dependent on MSCI coverage of the assets of the Fund and the Master Fund.

The Investment Manager will use this MSCI data to ensure it meets the binding environmental or social characteristics promoted by the Fund and the Master Fund.

Engagement

Where possible and deemed necessary, analysts engage in ongoing dialogue with senior leadership of issuers to assess their business model resilience and responsiveness to the environmental, social, and governance risk factors impacting their business.

Engagement policies

Engagement is a core part of the investment process in terms of due diligence and ongoing monitoring.

The Investment Manager intends to engage with issuers to understand their sustainability strategy, obtain better data and facilitate the Fund and Master Fund’s sustainability commitments and reporting.

Should a controversy and/or reason to be concerned about the investment’s alignment to the environmental and/or social characteristics arise, an engagement plan will be compiled to monitor and remediate, where practicable.

Designated reference benchmark

No specific index has been designated as a reference benchmark for the purpose of attaining the environmental and/or social characteristics promoted by the Fund or the Master Fund.

FURTHER INFORMATION

This SRD is issued for information purposes only in accordance with the requirements of SFDR. It is not intended as investment advice and is not an offer or a recommendation about managing or investing assets.

The information contained herein is current as of the date of issuance and is subject to change without notice.

Past performance is not a guarantee or a reliable indicator of future results and an investment could lose value. All investments involve risk, including the possible loss of capital.

The Manager's registered office at 20-on-Hatch, Hatch Street Lower, Dublin 2, Ireland.

The Manager is authorised in Ireland and regulated by the Central Bank.

Sustainability-related disclosures

This sustainability-related disclosure ("SRD") is accurate as at: 27 August 2025

This SRD is issued by MetLife Investment Management Europe Limited (the "Manager") and contains information relating specifically to MetLife Feeder Fund I (the “Fund”), an open-ended sub-fund of MetLife Investment Management RIAIF ICAV (the “ICAV”), an umbrella Irish collective asset-management vehicle with segregated liability between sub-funds governed by the laws of Ireland and authorised as a retail investor alternative investment fund under the Alternative Investment Fund Managers Directive 2011, as amended (the "AIFMD") by the Central Bank of Ireland (the "Central Bank"). MetLife Investment Management LLC serves as the investment manager to the Fund (the “Investment Manager”).

Pursuant to the Sustainable Finance Disclosure Regulation (Regulation EU/2019/2088) as amended ("SFDR"), the Fund discloses pursuant to Article 8 of SFDR as a financial product which promotes, among other characteristics, environmental or social characteristics, or a combination of those characteristics, provided that the companies in which the investments are made follow good governance practices.

This SRD has been prepared for the purpose of meeting the website disclosure requirements under Article 10 of SFDR relating to the Fund. 

For further details on the Fund and the ICAV, please refer to currently issued version of the ICAV's Prospectus, the Supplement in respect of the Fund and the latest annual report which may be obtained free of charge on request.

Summary
The Fund promotes environmental and social characteristics but does not have sustainable investment as its objective

The Fund is a feeder fund of the MetLife Sterling Short-Term Fixed Income Fund (the “Master Fund”). The information provided here is aligned to the information provided by the Master Fund.

The environmental and social characteristics promoted by the Master Fund are: (1) a reduction in GHG emissions; and (2) a reduction in the production and distribution of controversial weapons.

As the Fund will invest at least 85% of its assets in the Master Fund, the environmental and social characteristics promoted by the Fund, are also: (1) a reduction in GHG emissions; and (2) a reduction in the production and distribution of controversial weapons. The investment strategy of the Fund is to invest at least 85% of its assets in the Master Fund and up to 15% in financial derivative instruments (“FDIs”). The investment objective of the Master Fund is the preservation of capital through investment in high quality assets. There is no assurance that such objective will be achieved. The Master Fund will seek to achieve its objective by investing primarily in a diversified portfolio of Investment Grade Fixed Income Securities either denominated in Sterling or hedged back to Sterling.

The minimum proportion of the investments of the Master Fund used to meet the environmental and social characteristics promoted by the Master Fund in accordance with the binding elements of the investment strategy will be 75%, with it being noted that the Master Fund has not committed to making sustainable investments in accordance with Article 2(17) of SFDR. Accordingly, noting that the Fund will invest at least 85% of its assets in the Master Fund, the minimum proportion of investments of the Fund used to meet the environmental and social characteristics promoted by the Fund will be 63.75% (which is 85% of 75%).

The binding element of the Fund’s investment strategy used to select the investments to attain the promoted characteristics is that it will invest at least 85% of its assets in the Master Fund. The binding elements of the Master Fund’s investment strategy used to select the investments to attain the promoted characteristics are:

  1. the employment of an exclusion screen in respect of companies exceeding revenue thresholds for thermal coal extraction, thermal power generation, and oil and gas production activities; and
  2. the employment of an exclusion screen in respect of companies that are involved in the production, sale and/or distribution of nuclear or other controversial weapons; and
  3. the consideration of the following PAIs:
    • 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).

The Investment Manager will also consider voluntary PAIs that are deemed applicable based on the relevant issuer and/or sector in which the issuer operates, and where data is readily available.

The Investment Manager will rely on data from MSCI (or a replacement data provider duly chosen and appointed by the Investment Manager) to monitor the revenue threshold requirements.

There are limitations regarding both methodologies and data. For some exposures, sustainability data is unavailable due to the lack of publicly disclosed information. Disclosure of ESG data is improving year-on-year with more companies publicly disclosing data to support the assessment of the environmental or social characteristics promoted by financial products.

Due diligence on underlying assets is carried out by reference to sustainability data and engagement.

A reference benchmark has not been designated for the purposes of assessing the environmental or social characteristics promoted by the Fund or the Master Fund.

 

No sustainable investment objective

The Fund promotes environmental or social characteristics but does not have sustainable investment as its objective.

Environmental or social characteristics of the financial product

The Fund is a feeder fund of the MetLife Sterling Short-Term Fixed Income Fund (the “Master Fund”). The information provided here is aligned to the information provided by the Master Fund.

The environmental and social characteristics promoted by the Master Fund are: (1) a reduction in GHG emissions; and (2) a reduction in the production and distribution of controversial weapons. As the Fund will invest at least 85% of its assets in the Master Fund, the environmental and social characteristics promoted by the Fund, are also: (1) a reduction in GHG emissions; and (2) a reduction in the production and distribution of controversial weapons.

Investment strategy

The investment strategy of the Fund is to invest at least 85% of its assets in the Master Fund and up to 15% in financial derivative instruments (“FDIs”). The investment objective of the Master Fund is the preservation of capital through investment in high quality assets. There is no assurance that such objective will be achieved. The Master Fund will seek to achieve its objective by investing primarily in a diversified portfolio of Investment Grade Fixed Income Securities either denominated in Sterling or hedged back to Sterling.

The Investment Manager believes fixed income markets are efficient with respect to interest rate risk, but regularly misprice securities that are exposed to credit, downgrade, and liquidity risks. The Investment Manager seeks to exploit inefficiencies in the market and provide investors with excess returns to the Master Fund Reference Index through (i) conducting proprietary, in-depth fundamental research, (ii) analysing capital structures and covenants, (iii) reviewing of management and industry trends, (iv) targeting duration-neutral portfolios and (v) constructing portfolios with attractive risk / reward characteristics.

The Investment Manager seeks to avoid investments associated with negative externalities through the consideration of PAIs and the application of exclusionary screens.

This strategy is implemented on a continuous basis through the ongoing consideration of the PAIs and the application of exclusionary screens, in addition to the requirements for the Investment Manager to manage the portfolio in accordance with the terms of the Master Fund Supplement (including the SFDR Annex).

Proportion of investments

The minimum proportion of the investments of the Master Fund used to meet the environmental and social characteristics promoted by the Master Fund in accordance with the binding elements of the investment strategy will be 75%, with it being noted that the Master Fund has not committed to making sustainable investments in accordance with Article 2(17) of SFDR. Accordingly, noting that the Fund will invest at least 85% of its assets in the Master Fund, the minimum proportion of investments of the Fund used to meet the environmental and social characteristics promoted by the Fund will be 63.75% (which is 85% of 75%).

The purpose of the remaining proportion of the investments within the ‘#2 Other’ category is (a) to adjust the equity and currency risk through the Fund’s use of FDIs and (b) for liquidity and cash management purposes. No minimum environmental or social safeguards are applied to these investments listed in (a) and (b). The remaining portion of the Fund’s “#2 Other” allocation (after (a) and (b) above) arises as a result of Master Fund’s “#2 Other” allocation – whilst the Fund is investing in the Master Fund for investment purposes, Master Fund’s “#2 Other” allocation will include CIS and money market instruments used by the Master Fund for liquidity and cash management purposes (with no minimum environmental or social safeguards being applied to these investments by the Master Fund).

Monitoring of environmental or social characteristics

The binding element of the Fund’s investment strategy used to select the investments to attain the promoted characteristics is that it will invest at least 85% of its assets in the Master Fund. The binding elements of the Master Fund’s investment strategy used to select the investments to attain the promoted characteristics are:

  1. the employment of an exclusion screen in respect of companies exceeding the following revenue thresholds for specified activities:

    Activity Revenue threshold
    Thermal coal extraction >5%
    Thermal power generation >5%
    Oil and gas production >5%

  2. the employment of an exclusion screen in respect of companies that are involved in the production, sale and/or distribution of nuclear or other controversial weapons; and
  3. the consideration of the following PAIs:
    • 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).

The Investment Manager will also consider voluntary PAIs that are deemed applicable based on the relevant issuer and/or sector in which the issuer operates, and where data is readily available.

Noting that the Fund may invest up to 15% of its assets in FDIs, due to the nature of these FDIs it is not possible to apply the exclusionary screens detailed above in respect of this portion of the portfolio (i.e., the portion of the Fund that is not invested in the Master Fund).

Methodologies

In order to measure the Fund’s and the Master Fund’s promotion of “a reduction in GHG emissions”, the Master Fund employs an exclusion screen in respect of companies exceeding the following revenue thresholds for specified activities:

Activity Revenue threshold
Thermal coal extraction >5%
Thermal power generation >5%
Oil and gas production >5%

The Master Fund promotes the reduction in GHG emissions by not investing in any such companies, and in turn the Master Fund does not provide capital to these types of companies (which by definition are, in the view of the Master Fund, high GHG emitting companies).

In order to measure the Master Fund’s promotion of “a reduction in the production and distribution of controversial weapons”, the Master Fund employs an exclusion screen in respect of companies that are involved in the production, sale and/or distribution of nuclear or other controversial weapons (including landmines, cluster weapons, depleted uranium, white phosphorous, incendiary weapons and biological/chemical weapons). Again, the Master Fund promotes the ‘reduction in the production and distribution of controversial weapons’ by not investing in any such companies, and in turn the Master Fund does not provide capital to these types of companies that are involved in the production, sale and/or distribution of nuclear or other controversial weapons.

In addition, the Investment Manager considers the following PAIs on the Master Fund:

  • 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).

The Investment Manager also considers voluntary PAIs that are deemed applicable based on the relevant issuer and/or sector in which the issuer operates, and where data is readily available. As the Fund will invest at least 85% of its assets in the Master Fund, the sustainability indicators that are used to measure the attainment of each of the environmental and social characteristics promoted by the Master Fund, are the same sustainability indicators that are used to measure the attainment of each of the environmental and social characteristics promoted by the Fund.

Data sources and processing

Data sources used

The Investment Manager will rely on data from MSCI (or a replacement data provider duly chosen and appointed by the Investment Manager) to monitor revenue threshold requirements.

Measures taken to ensure data quality

The Investment Manager takes due care in selecting sustainability data providers as well as underlying sustainability research models and datapoints to anticipate and, where possible, mitigate limitations in the sustainability data quality and availability.

Should the Investment Manager determine that data provided to it by MSCI (or such replacement data provider) is incomplete or incorrect, the Investment Manager may use other sources available to it which it reasonably believes to be accurate.

How data is processed

The data referred to above is fed into the Investment Manager’s trading system as pre-trade rules to prevent the Master Fund from trading in the securities of excluded issuers.

Data is processed in accordance with applicable local laws on processing of data and in accordance with the Investment Manager's policies on data processing.

Proportion of data that is estimated

The Investment Manager only uses data as provided from the relevant sources in selecting relevant investments and in applying exclusion criteria. In some cases, the data provided by relevant sources may be estimated and the Investment Manager may also estimate data based on relevant methodologies.

Limitations to methodologies and data

There are limitations regarding both methodologies and data. For some issuers sustainability data is limited and/or unavailable due to the lack of publicly disclosed information. Disclosure of sustainability data is improving year-on-year with more issuers publicly disclosing data to support the assessment of the environmental or social characteristics promoted by financial products.

The data used is provided by external data providers and may contain inaccurate or incomplete data. In case of insufficient data, these data providers may rely on estimates and approximations using internal methodologies that may be subjective. These methodologies may also vary for each data provider. Differences in methodologies may also persist among issuer-reported data.

As the Investment Manager’s process relies on this data when making investment decisions, the data limitations noted above will in turn limit the process and may have an impact on our ability to measure whether the promoted characteristics are met and/or negative consequences for the Master Fund.

However, these challenges may be mitigated by issuer engagement and the Investment Manager does not expect these constraints to have a material impact on its ability to achieve the environmental or social characteristics promoted by the Master Fund.

SFDR seeks to achieve more transparency on how financial market participants integrate sustainability risks into their investment decisions and consideration of adverse sustainability impacts in the investment process. Data constraint is one of the biggest challenges when it comes to providing sustainability related information to end-investors, especially in the case of principal adverse impacts of investment decisions. There are also limitations on sustainability and ESG-related data provided by market participants on comparability.

Due diligence

Due diligence on underlying assets is carried out by reference to:

Sustainability Data

The Investment Manager will use the MSCI data to monitor GHG intensity and the revenue threshold requirements. All sustainability data is dependent on MSCI coverage of the assets of the Fund and the Master Fund.

The Investment Manager will use this MSCI data to ensure it meets the binding environmental or social characteristics promoted by the Fund and the Master Fund.

Engagement

Where possible and deemed necessary, analysts engage in ongoing dialogue with senior leadership of issuers to assess their business model resilience and responsiveness to the environmental, social, and governance risk factors impacting their business.

Engagement policies

The Investment Manager's approach to engagement is detailed in the MetLife Investment Management Stewardship Policy (which is available on request).

Engagement is a core part of the investment process in terms of due diligence and ongoing monitoring. Where possible and deemed necessary, the Investment Manager intends to engage with issuers to understand their sustainability strategy, obtain better data and facilitate the Fund and Master Fund’s sustainability commitments and reporting.

Should a controversy and/or reason to be concerned about the investment’s alignment to the environmental and/or social characteristics arise, an engagement plan will be compiled to monitor and remediate, where practicable.

Designated reference benchmark

No specific index has been designated as a reference benchmark for the purpose of attaining the environmental and/or social characteristics promoted by the Fund or the Master Fund.

FURTHER INFORMATION

This SRD is issued for information purposes only in accordance with the requirements of SFDR. It is not intended as investment advice and is not an offer or a recommendation about managing or investing assets.

The information contained herein is current as of the date of issuance and is subject to change without notice.

Past performance is not a guarantee or a reliable indicator of future results and an investment could lose value. All investments involve risk, including the possible loss of capital.

The Manager's registered office at 20-on-Hatch, Hatch Street Lower, Dublin 2, Ireland.

The Manager is authorised in Ireland and regulated by the Central Bank.

Sustainability-related disclosures

This sustainability-related disclosure ("SRD") is accurate as at: 27 August 2025

This SRD is issued by MetLife Investment Management Europe Limited (the "Manager") and contains information relating specifically to MetLife Feeder Fund II (the “Fund”), an open-ended sub-fund of MetLife Investment Management RIAIF ICAV (the “ICAV”), an umbrella Irish collective asset-management vehicle with segregated liability between sub-funds governed by the laws of Ireland and authorised as a retail investor alternative investment fund under the Alternative Investment Fund Managers Directive 2011, as amended (the "AIFMD") by the Central Bank of Ireland (the "Central Bank"). MetLife Investment Management LLC serves as the investment manager to the Fund (the “Investment Manager”).

Pursuant to the Sustainable Finance Disclosure Regulation (Regulation EU/2019/2088) as amended ("SFDR"), the Fund discloses pursuant to Article 8 of SFDR as a financial product which promotes, among other characteristics, environmental or social characteristics, or a combination of those characteristics, provided that the companies in which the investments are made follow good governance practices.

This SRD has been prepared for the purpose of meeting the website disclosure requirements under Article 10 of SFDR relating to the Fund.

For further details on the Fund and the ICAV, please refer to currently issued version of the ICAV's Prospectus, the Supplement in respect of the Fund and the latest annual report which may be obtained free of charge on request.

Summary
The Fund promotes environmental and social characteristics but does not have sustainable investment as its objective

The Fund is a feeder fund of the MetLife Sterling Short-Term Fixed Income Fund (the “Master Fund”). The information provided here is aligned to the information provided by the Master Fund.

The environmental and social characteristics promoted by the Master Fund are: (1) a reduction in GHG emissions; and (2) a reduction in the production and distribution of controversial weapons. As the Fund will invest at least 85% of its assets in the Master Fund, the environmental and social characteristics promoted by the Fund, are also: (1) a reduction in GHG emissions; and (2) a reduction in the production and distribution of controversial weapons.

The investment strategy of the Fund is to invest at least 85% of its assets in the Master Fund and up to 15% in financial derivative instruments (“FDIs”). The investment objective of the Master Fund is the preservation of capital through investment in high quality assets. There is no assurance that such objective will be achieved. The Master Fund will seek to achieve its objective by investing primarily in a diversified portfolio of Investment Grade Fixed Income Securities either denominated in Sterling or hedged back to Sterling.

The minimum proportion of the investments of the Master Fund used to meet the environmental and social characteristics promoted by the Master Fund in accordance with the binding elements of the investment strategy will be 75%, with it being noted that the Master Fund has not committed to making sustainable investments in accordance with Article 2(17) of SFDR. Accordingly, noting that the Fund will invest at least 85% of its assets in the Master Fund, the minimum proportion of investments of the Fund used to meet the environmental and social characteristics promoted by the Fund will be 63.75% (which is 85% of 75%).

The binding element of the Fund’s investment strategy used to select the investments to attain the promoted characteristics is that it will invest at least 85% of its assets in the Master Fund. The binding elements of the Master Fund’s investment strategy used to select the investments to attain the promoted characteristics are:

  1. the employment of an exclusion screen in respect of companies exceeding revenue thresholds for thermal coal extraction, thermal power generation, and oil and gas production activities; and
  2. the employment of an exclusion screen in respect of companies that are involved in the production, sale and/or distribution of nuclear or other controversial weapons; and
  3. the consideration of the following PAIs:
    • 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).

The Investment Manager will also consider voluntary PAIs that are deemed applicable based on the relevant issuer and/or sector in which the issuer operates, and where data is readily available.

The Investment Manager will rely on data from MSCI (or a replacement data provider duly chosen and appointed by the Investment Manager) to monitor the revenue threshold requirements.

There are limitations regarding both methodologies and data. For some exposures, sustainability data is unavailable due to the lack of publicly disclosed information. Disclosure of ESG data is improving year-on-year with more companies publicly disclosing data to support the assessment of the environmental or social characteristics promoted by financial products.

Due diligence on underlying assets is carried out by reference to sustainability data and engagement.

A reference benchmark has not been designated for the purposes of assessing the environmental or social characteristics promoted by the Fund or the Master Fund.

No sustainable investment objective

The Fund promotes environmental or social characteristics but does not have sustainable investment as its objective.

Environmental or social characteristics of the financial product

The Fund is a feeder fund of the MetLife Sterling Short-Term Fixed Income Fund (the “Master Fund”). The information provided here is aligned to the information provided by the Master Fund.

The environmental and social characteristics promoted by the Master Fund are: (1) a reduction in GHG emissions; and (2) a reduction in the production and distribution of controversial weapons. As the Fund will invest at least 85% of its assets in the Master Fund, the environmental and social characteristics promoted by the Fund, are also: (1) a reduction in GHG emissions; and (2) a reduction in the production and distribution of controversial weapons.

Investment strategy

The investment strategy of the Fund is to invest at least 85% of its assets in the Master Fund and up to 15% in financial derivative instruments (“FDIs”). The investment objective of the Master Fund is the preservation of capital through investment in high quality assets. There is no assurance that such objective will be achieved. The Master Fund will seek to achieve its objective by investing primarily in a diversified portfolio of Investment Grade Fixed Income Securities either denominated in Sterling or hedged back to Sterling.

The Investment Manager believes fixed income markets are efficient with respect to interest rate risk, but regularly misprice securities that are exposed to credit, downgrade, and liquidity risks. The Investment Manager seeks to exploit inefficiencies in the market and provide investors with excess returns to the Master Fund Reference Index through (i) conducting proprietary, in-depth fundamental research, (ii) analysing capital structures and covenants, (iii) reviewing of management and industry trends, (iv) targeting duration-neutral portfolios and (v) constructing portfolios with attractive risk / reward characteristics.

The Investment Manager seeks to avoid investments associated with negative externalities through the consideration of PAIs and the application of exclusionary screens.

This strategy is implemented on a continuous basis through the ongoing consideration of the PAIs and the application of exclusionary screens, in addition to the requirements for the Investment Manager to manage the portfolio in accordance with the terms of the Master Fund Supplement (including the SFDR Annex).

Proportion of investments

The minimum proportion of the investments of the Master Fund used to meet the environmental and social characteristics promoted by the Master Fund in accordance with the binding elements of the investment strategy will be 75%, with it being noted that the Master Fund has not committed to making sustainable investments in accordance with Article 2(17) of SFDR. Accordingly, noting that the Fund will invest at least 85% of its assets in the Master Fund, the minimum proportion of investments of the Fund used to meet the environmental and social characteristics promoted by the Fund will be 63.75% (which is 85% of 75%).

The purpose of the remaining proportion of the investments within the ‘#2 Other’ category is (a) to adjust the equity and currency risk through the Fund’s use of FDIs and (b) for liquidity and cash management purposes. No minimum environmental or social safeguards are applied to these investments listed in (a) and (b). The remaining portion of the Fund’s “#2 Other” allocation (after (a) and (b) above) arises as a result of Master Fund’s “#2 Other” allocation – whilst the Fund is investing in the Master Fund for investment purposes, Master Fund’s “#2 Other” allocation will include CIS and money market instruments used by the Master Fund for liquidity and cash management purposes (with no minimum environmental or social safeguards being applied to these investments by the Master Fund).

Monitoring of environmental or social characteristics

The binding element of the Fund’s investment strategy used to select the investments to attain the promoted characteristics is that it will invest at least 85% of its assets in the Master Fund. The binding elements of the Master Fund’s investment strategy used to select the investments to attain the promoted characteristics are:

  1. the employment of an exclusion screen in respect of companies exceeding the following revenue thresholds for specified activities:

    Activity Revenue threshold
    Thermal coal extraction >5%
    Thermal power generation >5%
    Oil and gas production >5%

  2. the employment of an exclusion screen in respect of companies that are involved in the production, sale and/or distribution of nuclear or other controversial weapons; and
  3. the consideration of the following PAIs:
    • 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).

The Investment Manager will also consider voluntary PAIs that are deemed applicable based on the relevant issuer and/or sector in which the issuer operates, and where data is readily available.

Noting that the Fund may invest up to 15% of its assets in FDIs, due to the nature of these FDIs it is not possible to apply the exclusionary screens detailed above in respect of this portion of the portfolio (i.e., the portion of the Fund that is not invested in the Master Fund).

Methodologies

In order to measure the Fund’s and the Master Fund’s promotion of “a reduction in GHG emissions”, the Master Fund employs an exclusion screen in respect of companies exceeding the following revenue thresholds for specified activities:

Activity Revenue threshold
Thermal coal extraction >5%
Thermal power generation >5%
Oil and gas production >5%

The Master Fund promotes the reduction in GHG emissions by not investing in any such companies, and in turn the Master Fund does not provide capital to these types of companies (which by definition are, in the view of the Master Fund, high GHG emitting companies).

In order to measure the Master Fund’s promotion of “a reduction in the production and distribution of controversial weapons”, the Master Fund employs an exclusion screen in respect of companies that are involved in the production, sale and/or distribution of nuclear or other controversial weapons (including landmines, cluster weapons, depleted uranium, white phosphorous, incendiary weapons and biological/chemical weapons). Again, the Master Fund promotes the ‘reduction in the production and distribution of controversial weapons’ by not investing in any such companies, and in turn the Master Fund does not provide capital to these types of companies that are involved in the production, sale and/or distribution of nuclear or other controversial weapons.

In addition, the Investment Manager considers the following PAIs on the Master Fund:

  • 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).

The Investment Manager also considers voluntary PAIs that are deemed applicable based on the relevant issuer and/or sector in which the issuer operates, and where data is readily available. As the Fund will invest at least 85% of its assets in the Master Fund, the sustainability indicators that are used to measure the attainment of each of the environmental and social characteristics promoted by the Master Fund, are the same sustainability indicators that are used to measure the attainment of each of the environmental and social characteristics promoted by the Fund.

Data sources and processing

Data sources used

The Investment Manager will rely on data from MSCI (or a replacement data provider duly chosen and appointed by the Investment Manager) to monitor revenue threshold requirements.

Measures taken to ensure data quality

The Investment Manager takes due care in selecting sustainability data providers as well as underlying sustainability research models and datapoints to anticipate and, where possible, mitigate limitations in the sustainability data quality and availability.

Should the Investment Manager determine that data provided to it by MSCI (or such replacement data provider) is incomplete or incorrect, the Investment Manager may use other sources available to it which it reasonably believes to be accurate.

How data is processed

The data referred to above is fed into the Investment Manager’s trading system as pre-trade rules to prevent the Master Fund from trading in the securities of excluded issuers.

Data is processed in accordance with applicable local laws on processing of data and in accordance with the Investment Manager's policies on data processing.

Proportion of data that is estimated

The Investment Manager only uses data as provided from the relevant sources in selecting relevant investments and in applying exclusion criteria. In some cases, the data provided by relevant sources may be estimated and the Investment Manager may also estimate data based on relevant methodologies.

Limitations to methodologies and data

There are limitations regarding both methodologies and data. For some issuers sustainability data is limited and/or unavailable due to the lack of publicly disclosed information. Disclosure of sustainability data is improving year-on-year with more issuers publicly disclosing data to support the assessment of the environmental or social characteristics promoted by financial products.

The data used is provided by external data providers and may contain inaccurate or incomplete data. In case of insufficient data, these data providers may rely on estimates and approximations using internal methodologies that may be subjective. These methodologies may also vary for each data provider. Differences in methodologies may also persist among issuer-reported data.

As the Investment Manager’s process relies on this data when making investment decisions, the data limitations noted above will in turn limit the process and may have an impact on our ability to measure whether the promoted characteristics are met and/or negative consequences for the Master Fund.

However, these challenges may be mitigated by issuer engagement and the Investment Manager does not expect these constraints to have a material impact on its ability to achieve the environmental or social characteristics promoted by the Master Fund.

SFDR seeks to achieve more transparency on how financial market participants integrate sustainability risks into their investment decisions and consideration of adverse sustainability impacts in the investment process. Data constraint is one of the biggest challenges when it comes to providing sustainability related information to end-investors, especially in the case of principal adverse impacts of investment decisions. There are also limitations on sustainability and ESG-related data provided by market participants on comparability.

Due diligence

Due diligence on underlying assets is carried out by reference to:

Sustainability Data

The Investment Manager will use the MSCI data to monitor GHG intensity and the revenue threshold requirements. All sustainability data is dependent on MSCI coverage of the assets of the Fund and the Master Fund.

The Investment Manager will use this MSCI data to ensure it meets the binding environmental or social characteristics promoted by the Fund and the Master Fund.

Engagement

Where possible and deemed necessary, analysts engage in ongoing dialogue with senior leadership of issuers to assess their business model resilience and responsiveness to the environmental, social, and governance risk factors impacting their business.

Engagement policies

The Investment Manager's approach to engagement is detailed in the MetLife Investment Management Stewardship Policy (which is available on request).

Engagement is a core part of the investment process in terms of due diligence and ongoing monitoring. Where possible and deemed necessary, the Investment Manager intends to engage with issuers to understand their sustainability strategy, obtain better data and facilitate the Fund and Master Fund’s sustainability commitments and reporting.

Should a controversy and/or reason to be concerned about the investment’s alignment to the environmental and/or social characteristics arise, an engagement plan will be compiled to monitor and remediate, where practicable.

Designated reference benchmark

No specific index has been designated as a reference benchmark for the purpose of attaining the environmental and/or social characteristics promoted by the Fund or the Master Fund.

FURTHER INFORMATION

This SRD is issued for information purposes only in accordance with the requirements of SFDR. It is not intended as investment advice and is not an offer or a recommendation about managing or investing assets.

The information contained herein is current as of the date of issuance and is subject to change without notice.

Past performance is not a guarantee or a reliable indicator of future results and an investment could lose value. All investments involve risk, including the possible loss of capital.

The Manager's registered office at 20-on-Hatch, Hatch Street Lower, Dublin 2, Ireland.

The Manager is authorised in Ireland and regulated by the Central Bank.

Sustainability-related disclosures

This sustainability-related disclosure ("SRD") is accurate as at: 27 August 2025

This SRD is issued by MetLife Investment Management Europe Limited (the "Manager") and contains information relating specifically to MetLife Feeder Fund III (the “Fund”), an open-ended sub-fund of MetLife Investment Management RIAIF ICAV (the “ICAV”), an umbrella Irish collective asset-management vehicle with segregated liability between sub-funds governed by the laws of Ireland and authorised as a retail investor alternative investment fund under the Alternative Investment Fund Managers Directive 2011, as amended (the "AIFMD") by the Central Bank of Ireland (the "Central Bank"). MetLife Investment Management LLC serves as the investment manager to the Fund (the “Investment Manager”).

Pursuant to the Sustainable Finance Disclosure Regulation (Regulation EU/2019/2088) as amended ("SFDR"), the Fund discloses pursuant to Article 8 of SFDR as a financial product which promotes, among other characteristics, environmental or social characteristics, or a combination of those characteristics, provided that the companies in which the investments are made follow good governance practices.

This SRD has been prepared for the purpose of meeting the website disclosure requirements under Article 10 of SFDR relating to the Fund.

For further details on the Fund and the ICAV, please refer to currently issued version of the ICAV's Prospectus, the Supplement in respect of the Fund and the latest annual report which may be obtained free of charge on request.

Summary
The Fund promotes environmental and social characteristics but does not have sustainable investment as its objective

The Fund is a feeder fund of the MetLife Sterling Short-Term Fixed Income Fund (the “Master Fund”). The information provided here is aligned to the information provided by the Master Fund.

The environmental and social characteristics promoted by the Master Fund are: (1) a reduction in GHG emissions; and (2) a reduction in the production and distribution of controversial weapons. As the Fund will invest at least 85% of its assets in the Master Fund, the environmental and social characteristics promoted by the Fund, are also: (1) a reduction in GHG emissions; and (2) a reduction in the production and distribution of controversial weapons.

The investment strategy of the Fund is to invest at least 85% of its assets in the Master Fund and up to 15% in financial derivative instruments (“FDIs”). The investment objective of the Master Fund is the preservation of capital through investment in high quality assets. There is no assurance that such objective will be achieved. The Master Fund will seek to achieve its objective by investing primarily in a diversified portfolio of Investment Grade Fixed Income Securities either denominated in Sterling or hedged back to Sterling.

The minimum proportion of the investments of the Master Fund used to meet the environmental and social characteristics promoted by the Master Fund in accordance with the binding elements of the investment strategy will be 75%, with it being noted that the Master Fund has not committed to making sustainable investments in accordance with Article 2(17) of SFDR. Accordingly, noting that the Fund will invest at least 85% of its assets in the Master Fund, the minimum proportion of investments of the Fund used to meet the environmental and social characteristics promoted by the Fund will be 63.75% (which is 85% of 75%).

The binding element of the Fund’s investment strategy used to select the investments to attain the promoted characteristics is that it will invest at least 85% of its assets in the Master Fund. The binding elements of the Master Fund’s investment strategy used to select the investments to attain the promoted characteristics are:

  1. the employment of an exclusion screen in respect of companies exceeding revenue thresholds for thermal coal extraction, thermal power generation, and oil and gas production activities; and
  2. the employment of an exclusion screen in respect of companies that are involved in the production, sale and/or distribution of nuclear or other controversial weapons; and
  3. the consideration of the following PAIs:
    • 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).

The Investment Manager will also consider voluntary PAIs that are deemed applicable based on the relevant issuer and/or sector in which the issuer operates, and where data is readily available.

The Investment Manager will rely on data from MSCI (or a replacement data provider duly chosen and appointed by the Investment Manager) to monitor the revenue threshold requirements.

There are limitations regarding both methodologies and data. For some exposures, sustainability data is unavailable due to the lack of publicly disclosed information. Disclosure of ESG data is improving year-on-year with more companies publicly disclosing data to support the assessment of the environmental or social characteristics promoted by financial products.

Due diligence on underlying assets is carried out by reference to sustainability data and engagement.

A reference benchmark has not been designated for the purposes of assessing the environmental or social characteristics promoted by the Fund or the Master Fund.

No sustainable investment objective

The Fund promotes environmental or social characteristics but does not have sustainable investment as its objective.

Environmental or social characteristics of the financial product

The Fund is a feeder fund of the MetLife Sterling Short-Term Fixed Income Fund (the “Master Fund”). The information provided here is aligned to the information provided by the Master Fund.

The environmental and social characteristics promoted by the Master Fund are: (1) a reduction in GHG emissions; and (2) a reduction in the production and distribution of controversial weapons. As the Fund will invest at least 85% of its assets in the Master Fund, the environmental and social characteristics promoted by the Fund, are also: (1) a reduction in GHG emissions; and (2) a reduction in the production and distribution of controversial weapons.

Investment strategy

The investment strategy of the Fund is to invest at least 85% of its assets in the Master Fund and up to 15% in financial derivative instruments (“FDIs”). The investment objective of the Master Fund is the preservation of capital through investment in high quality assets. There is no assurance that such objective will be achieved. The Master Fund will seek to achieve its objective by investing primarily in a diversified portfolio of Investment Grade Fixed Income Securities either denominated in Sterling or hedged back to Sterling.

The Investment Manager believes fixed income markets are efficient with respect to interest rate risk, but regularly misprice securities that are exposed to credit, downgrade, and liquidity risks. The Investment Manager seeks to exploit inefficiencies in the market and provide investors with excess returns to the Master Fund Reference Index through (i) conducting proprietary, in-depth fundamental research, (ii) analysing capital structures and covenants, (iii) reviewing of management and industry trends, (iv) targeting duration-neutral portfolios and (v) constructing portfolios with attractive risk / reward characteristics.

The Investment Manager seeks to avoid investments associated with negative externalities through the consideration of PAIs and the application of exclusionary screens.

This strategy is implemented on a continuous basis through the ongoing consideration of the PAIs and the application of exclusionary screens, in addition to the requirements for the Investment Manager to manage the portfolio in accordance with the terms of the Master Fund Supplement (including the SFDR Annex).

Proportion of investments

The minimum proportion of the investments of the Master Fund used to meet the environmental and social characteristics promoted by the Master Fund in accordance with the binding elements of the investment strategy will be 75%, with it being noted that the Master Fund has not committed to making sustainable investments in accordance with Article 2(17) of SFDR. Accordingly, noting that the Fund will invest at least 85% of its assets in the Master Fund, the minimum proportion of investments of the Fund used to meet the environmental and social characteristics promoted by the Fund will be 63.75% (which is 85% of 75%).

The purpose of the remaining proportion of the investments within the ‘#2 Other’ category is (a) to adjust the equity and currency risk through the Fund’s use of FDIs and (b) for liquidity and cash management purposes. No minimum environmental or social safeguards are applied to these investments listed in (a) and (b). The remaining portion of the Fund’s “#2 Other” allocation (after (a) and (b) above) arises as a result of Master Fund’s “#2 Other” allocation – whilst the Fund is investing in the Master Fund for investment purposes, Master Fund’s “#2 Other” allocation will include CIS and money market instruments used by the Master Fund for liquidity and cash management purposes (with no minimum environmental or social safeguards being applied to these investments by the Master Fund).

Monitoring of environmental or social characteristics

The binding element of the Fund’s investment strategy used to select the investments to attain the promoted characteristics is that it will invest at least 85% of its assets in the Master Fund. The binding elements of the Master Fund’s investment strategy used to select the investments to attain the promoted characteristics are:

  1. the employment of an exclusion screen in respect of companies exceeding the following revenue thresholds for specified activities:

    Activity Revenue threshold
    Thermal coal extraction >5%
    Thermal power generation >5%
    Oil and gas production >5%

  2. the employment of an exclusion screen in respect of companies that are involved in the production, sale and/or distribution of nuclear or other controversial weapons; and
  3. the consideration of the following PAIs:
    • 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).

The Investment Manager will also consider voluntary PAIs that are deemed applicable based on the relevant issuer and/or sector in which the issuer operates, and where data is readily available.

Noting that the Fund may invest up to 15% of its assets in FDIs, due to the nature of these FDIs it is not possible to apply the exclusionary screens detailed above in respect of this portion of the portfolio (i.e., the portion of the Fund that is not invested in the Master Fund).

Methodologies

In order to measure the Fund’s and the Master Fund’s promotion of “a reduction in GHG emissions”, the Master Fund employs an exclusion screen in respect of companies exceeding the following revenue thresholds for specified activities:

Activity Revenue threshold
Thermal coal extraction >5%
Thermal power generation >5%
Oil and gas production >5%

The Master Fund promotes the reduction in GHG emissions by not investing in any such companies, and in turn the Master Fund does not provide capital to these types of companies (which by definition are, in the view of the Master Fund, high GHG emitting companies).

In order to measure the Master Fund’s promotion of “a reduction in the production and distribution of controversial weapons”, the Master Fund employs an exclusion screen in respect of companies that are involved in the production, sale and/or distribution of nuclear or other controversial weapons (including landmines, cluster weapons, depleted uranium, white phosphorous, incendiary weapons and biological/chemical weapons). Again, the Master Fund promotes the ‘reduction in the production and distribution of controversial weapons’ by not investing in any such companies, and in turn the Master Fund does not provide capital to these types of companies that are involved in the production, sale and/or distribution of nuclear or other controversial weapons.

In addition, the Investment Manager considers the following PAIs on the Master Fund:

  • 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).

The Investment Manager also considers voluntary PAIs that are deemed applicable based on the relevant issuer and/or sector in which the issuer operates, and where data is readily available. As the Fund will invest at least 85% of its assets in the Master Fund, the sustainability indicators that are used to measure the attainment of each of the environmental and social characteristics promoted by the Master Fund, are the same sustainability indicators that are used to measure the attainment of each of the environmental and social characteristics promoted by the Fund.

Data sources and processing

Data sources used

The Investment Manager will rely on data from MSCI (or a replacement data provider duly chosen and appointed by the Investment Manager) to monitor revenue threshold requirements.

Measures taken to ensure data quality

The Investment Manager takes due care in selecting sustainability data providers as well as underlying sustainability research models and datapoints to anticipate and, where possible, mitigate limitations in the sustainability data quality and availability.

Should the Investment Manager determine that data provided to it by MSCI (or such replacement data provider) is incomplete or incorrect, the Investment Manager may use other sources available to it which it reasonably believes to be accurate.

How data is processed

The data referred to above is fed into the Investment Manager’s trading system as pre-trade rules to prevent the Master Fund from trading in the securities of excluded issuers.

Data is processed in accordance with applicable local laws on processing of data and in accordance with the Investment Manager's policies on data processing.

Proportion of data that is estimated

The Investment Manager only uses data as provided from the relevant sources in selecting relevant investments and in applying exclusion criteria. In some cases, the data provided by relevant sources may be estimated and the Investment Manager may also estimate data based on relevant methodologies.

Limitations to methodologies and data

There are limitations regarding both methodologies and data. For some issuers sustainability data is limited and/or unavailable due to the lack of publicly disclosed information. Disclosure of sustainability data is improving year-on-year with more issuers publicly disclosing data to support the assessment of the environmental or social characteristics promoted by financial products.

The data used is provided by external data providers and may contain inaccurate or incomplete data. In case of insufficient data, these data providers may rely on estimates and approximations using internal methodologies that may be subjective. These methodologies may also vary for each data provider. Differences in methodologies may also persist among issuer-reported data.

As the Investment Manager’s process relies on this data when making investment decisions, the data limitations noted above will in turn limit the process and may have an impact on our ability to measure whether the promoted characteristics are met and/or negative consequences for the Master Fund.

However, these challenges may be mitigated by issuer engagement and the Investment Manager does not expect these constraints to have a material impact on its ability to achieve the environmental or social characteristics promoted by the Master Fund.

SFDR seeks to achieve more transparency on how financial market participants integrate sustainability risks into their investment decisions and consideration of adverse sustainability impacts in the investment process. Data constraint is one of the biggest challenges when it comes to providing sustainability related information to end-investors, especially in the case of principal adverse impacts of investment decisions. There are also limitations on sustainability and ESG-related data provided by market participants on comparability.

Due diligence

Due diligence on underlying assets is carried out by reference to:

Sustainability Data

The Investment Manager will use the MSCI data to monitor GHG intensity and the revenue threshold requirements. All sustainability data is dependent on MSCI coverage of the assets of the Fund and the Master Fund.

The Investment Manager will use this MSCI data to ensure it meets the binding environmental or social characteristics promoted by the Fund and the Master Fund.

Engagement

Where possible and deemed necessary, analysts engage in ongoing dialogue with senior leadership of issuers to assess their business model resilience and responsiveness to the environmental, social, and governance risk factors impacting their business.

Engagement policies

The Investment Manager's approach to engagement is detailed in the MetLife Investment Management Stewardship Policy (which is available on request).

Engagement is a core part of the investment process in terms of due diligence and ongoing monitoring. Where possible and deemed necessary, the Investment Manager intends to engage with issuers to understand their sustainability strategy, obtain better data and facilitate the Fund and Master Fund’s sustainability commitments and reporting.

Should a controversy and/or reason to be concerned about the investment’s alignment to the environmental and/or social characteristics arise, an engagement plan will be compiled to monitor and remediate, where practicable.

Designated reference benchmark

No specific index has been designated as a reference benchmark for the purpose of attaining the environmental and/or social characteristics promoted by the Fund or the Master Fund.

FURTHER INFORMATION

This SRD is issued for information purposes only in accordance with the requirements of SFDR. It is not intended as investment advice and is not an offer or a recommendation about managing or investing assets.

The information contained herein is current as of the date of issuance and is subject to change without notice.

Past performance is not a guarantee or a reliable indicator of future results and an investment could lose value. All investments involve risk, including the possible loss of capital.

The Manager's registered office at 20-on-Hatch, Hatch Street Lower, Dublin 2, Ireland.

The Manager is authorised in Ireland and regulated by the Central Bank.