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Gabelli Funds

Funds Group: Gabelli Funds

Management Company: Gabelli Funds, LLC

Funds Affected: Gabelli ESG Fund

Principal Sustainable Investment Management Strategy: ESG Integration, Exclusions

Summary:

The fund combines a differentiated, value-oriented investment philosophy with social screens and a holistic ESG (Environmental, Social, Governance) analysis to deliver returns in a socially responsive manner. The fund’s adviser employs a social screening overlay process at the time of investment to identify companies that meet the fund’s social guidelines. Pursuant to the guidelines, the fund will not invest in publicly traded fossil fuel (coal, oil, and gas) companies, the top 50 defense/weapons contractors, or in companies that derive more than 5% of their revenues from the following areas: tobacco, alcohol, gaming, defense/weapons production, and companies involved in the manufacture of abortion related products. The fund utilizes MSCI’s ESG ratings to assist in its holistic analysis of each company considered for investment.

After identifying companies that satisfy these social criteria, Gabelli then will invest in securities of companies that the Adviser believes are trading at a material discount to PMV. Gabelli monitors each holding on a regular basis to ensure its compliance with the fund’s guidelines.