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Harbor Capital

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Fund Complex: Harbor Capital
Management Company: (1) Harbor Capital Advisors, Inc.; subadviser: Shenkman Capital Management, Inc. (2) Subadviser: Comgest Asset Management International Limited (CAMIL). In providing services to Harbor Focused International Fund, CAMIL uses designated persons of its affiliates, including Comgest S.A., based in Paris, France, and Comgest Singapore Pte Ltd., based in Singapore. CAMIL and such affiliates are referred to collectively, as Comgest, (3) Harbor Capital Advisors, Inc.; subadviser:  Robeco International Asset Management US Inc. (an affiliate of the Adviser)
Funds Affected: (1) Harbor Convertible Securities Fund, (2) Harbor Focused International Fund, (3) Harbor Robeco Emerging Markets Active Equities Fund, Harbor Robeco Emerging Markets Conservative Equities Fund, Harbor Robeco Global Conservative Equities Fund, Harbor Robeco International Conservative Equities Fund and Harbor Robeco US Conservative Equities Fund
Sustainable Investing Strategies: (1-3) ESG integration
Summary:
(1) The subadviser may consider environmental, social, and governance (ESG) factors that might impact a company’s future prospects, operating performance, or valuation.
Note: ESG strategy effective March 1, 2019.
(2) The subadviser’s investment process employs fundamental, bottom-up research to assess company quality, growth drivers, and risks. The process combines financial analysis with field research, including meetings with company management, operational staff, and suppliers, and includes an analysis of each company’s competitive environment. The subadviser’s assessment of company quality also includes an analysis of environmental, social and governance factors.
(3) The subadviser systematically incorporates an analysis of environmental, social, and governance (ESG) factors into its investment process, by using ESG scores derived from the RobecoSAM Corporate Sustainability Assessment (which assigns companies a RobecoSAM smart ESG score of between 0 (low) and 100 (high) based on a range of environmental, social and corporate governance factors). The subadviser aims to construct a portfolio that has a total weighted ESG score that is at least as high as the total weighted ESG score which is calculated by applying the RobecoSAM scores to the MSCI Emerging Markets (ND) Index.

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