This is about a Baillie Gifford climate-focused fund that invests in global stocks while avoiding polluting companies. It badly lagged the world stock market over the past six months and one year, partly because its climate screening narrows the pool of stocks it can own. Its top holdings include TSMC and NVIDIA, both big chipmakers benefiting from the AI boom, plus Google's parent Alphabet. The fund suits patient investors who can tolerate up-and-down returns for five years or more, not those wanting steady income or capital protection.
This report introduces the investment strategy and performance of the Baillie Gifford Global Alpha Paris Aligned Fund. The fund aims to outperform the MSCI ACWI Index on a rolling five-year basis while maintaining a carbon footprint below the EU Paris Aligned benchmark, achieving net-zero targets th
For the six months ended June 30, 2026, the Fund's B share class returned 2.5%, while the MSCI ACWI Index rose 13.0% over the same period, a shortfall of 10.5 percentage points; the one-year return was 11.1% versus the Index's 28.2%, underperforming by 17.1 percentage points.
| Measure | 6 months | 1 year | 3 years (annualised) | 5 years (annualised) |
|---|---|---|---|---|
| Fund B-Acc (%) | 2.5 | 11.1 | 10.5 | 1.9 |
| MSCI ACWI Index (%) | 13.0 | 28.2 | 18.5 | 12.4 |
| IA Global sector average (%) | 10.1 | 21.4 | 13.4 | 8.1 |
| Year ended June 30 | 2021/22 | 2022/23 | 2023/24 | 2024/25 | 2025/26 |
|---|---|---|---|---|---|
| Fund B-Acc (%) | -26.3 | 10.5 | 14.3 | 6.2 | 11.1 |
| MSCI ACWI Index (%) | -3.7 | 11.9 | 20.6 | 7.6 | 28.2 |
| IA sector average (%) | -8.8 | 10.8 | 14.9 | 4.6 | 21.4 |
Since the Fund's inception in April 2021, it has underperformed the Index over every full annual period; peer rankings are likewise weak: 399/441 over five years, 344/502 over three years, and 493/578 over six months. The report notes that share-class returns are calculated using 10 a.m. prices and index returns using closing prices; both are total returns in sterling after the deduction of fees.
The Fund targets outperformance of the MSCI ACWI Index on a rolling five-year basis, with a carbon footprint below that of the MSCI ACWI EU Paris Aligned benchmark index, advancing a path to net zero by 2050 through a four-stage screening process; the managers also use the IA Global sector average as a performance reference.
This page does not disclose monthly purchases, sales, or position increases/decreases, but it does provide allocation deviations relative to the MSCI ACWI: notably overweight consumer discretionary and communication services at the sector level, and significantly underweight the United States with overweights in Taiwan and China at the regional level.
Top ten holdings (% of total assets):
| Holding | Weight (%) |
|---|---|
| TSMC | 5.9 |
| NVIDIA | 5.3 |
| Alphabet | 3.8 |
| Amazon.com | 3.6 |
| Samsung Electronics | 2.5 |
| Microsoft | 2.3 |
| Tencent | 2.0 |
| CATL | 2.0 |
| Mastercard | 1.9 |
| Meta Platforms | 1.8 |
Sector allocation:
| Sector | Fund (%) | Index (%) | Difference (pp) |
|---|---|---|---|
| Information Technology | 30.8 | 32.1 | -1.3 |
| Financials | 14.1 | 16.2 | -2.1 |
| Consumer Discretionary | 13.8 | 8.7 | +5.1 |
| Industrials | 12.3 | 11.0 | +1.3 |
| Communication Services | 10.7 | 7.8 | +2.9 |
| Health Care | 8.9 | 8.3 | +0.7 |
| Materials | 4.1 | 3.6 | +0.5 |
| Consumer Staples | 3.3 | 4.7 | -1.5 |
| Real Estate | 1.3 | 1.6 | -0.2 |
| Cash | 0.7 | 0.0 | +0.7 |
Top ten regions:
| Region | Fund (%) | Index (%) | Difference (pp) |
|---|---|---|---|
| United States | 57.9 | 63.6 | -5.8 |
| Taiwan | 6.8 | 3.3 | +3.5 |
| Japan | 5.6 | 5.0 | +0.6 |
| China | 5.0 | 2.3 | +2.7 |
| South Korea | 3.4 | 2.9 | +0.5 |
| Brazil | 3.0 | 0.5 | +2.5 |
| Ireland | 2.5 | 0.1 | +2.4 |
| Canada | 2.2 | 2.9 | -0.8 |
| Sweden | 2.0 | 0.7 | +1.3 |
| United Kingdom | 1.6 | 3.0 | -1.4 |
The Fund has assets of £405.69 million, holds 89 positions, with an active share of 79% and annual turnover of 44%, co-managed by three partner-level managers.
As a sequel, this section focuses on the legal entity structure, target market definitions, risk disclosure framework, and cross-border regulatory compliance provisions in the Fund documents. On the surface these appear to be standard legal statements, but read closely, they reveal the Fund's product positioning, distribution strategy, and the tensions inherent in the strategy.
The document opens by clarifying the relationship between two legal entities:
Both are regulated by the UK Financial Conduct Authority (FCA). This structural arrangement is noteworthy: a product aimed at global investors is nonetheless uniformly backstopped by the UK regulatory system. The compliance logic behind this is that the fund is likely established under UCITS or NURS (Non-UCITS Retail Scheme) rules, allowing it to be registered in the UK and then enter other markets through the "passport" mechanism or private placement exemptions.
Table: Entity Functions and Regulatory Oversight
| Entity | Function | Regulator |
|---|---|---|
| Baillie Gifford & Co Limited | Publishes fact sheet; fund operating entity | FCA |
| Baillie Gifford Overseas Limited | Non-UK client services; cross-border advisory | FCA |
The report adds: The dual-entity arrangement allows the fund to flexibly switch between "UK entity" and "offshore entity" status when selling into different jurisdictions, thereby circumventing additional registration requirements that some countries impose on "foreign fund managers." This also explains the separate legal notices for six countries (Israel, Colombia, Chile, Peru, Mexico) that appear later in the document — each notice is a response to local regulatory warnings regarding "unregistered products."
The document describes the target market as “suitable for all investors seeking long-term capital appreciation,” while also setting out explicit exclusion criteria:
This definition adopts the phrasing of “mass market distribution”, meaning the fund can theoretically be sold through retail channels. However, the exclusion criteria in effect narrow the target clientele to investors with a long-term horizon, who can tolerate losses, and whose core needs are not centered on cash flow—a group closer to private banking clients or high-net-worth individuals.
Table: Investor Characteristics Fit
| Dimension | Compatible Mass Investors | Unsuitable Investors |
|---|---|---|
| Investment horizon | ≥5 years | <5 years |
| Income needs | Accept no regular dividends | Depend on stable cash flow |
| Risk appetite | Accept NAV fluctuations and loss of principal | Averse to volatility, require capital preservation |
| Value orientation | Accept opportunity cost of carbon screening | Purely seek maximum returns, unwilling to be constrained by screening |
Additional Insight: Turning “carbon screening” from an investment strategy feature into a “restrictive condition” explicitly warns investors—this means only a narrower investment universe than unrestricted funds, and therefore returns may systematically deviate from comparable funds not bound by ESG constraints. This is a very candid formulation: it does not package the Paris-Aligned strategy as a “sure-win ESG advantage,” but instead lists this deviation as a risk factor. For investors genuinely concerned about climate transition, this candor actually enhances credibility; but for investors who aim solely at maximizing returns, it serves as an ex ante disclaimer.
The specific risks listed in the document include:
1. Emerging market custody risk (custodian insolvency / breach of duty)
2. Emerging market trading liquidity risk (difficulties in trading)
3. Currency risk (foreign currency exposure)
4. Fund price volatility risk (based on the market value of underlying holdings and the pricing model)
But it also implies a fifth risk—performance deviation risk arising from carbon screening—which appears as a standalone paragraph near the end of the risk list:
> “The Fund employs carbon screens which means it cannot invest in certain companies. The universe of available investments will be more limited than other funds that do not apply such criteria/exclusions, therefore the Fund may have different returns than a fund which has no such restrictions.”
This means the fund simultaneously bears dual active deviation risks: one is the fund manager's stock-selection deviation (the style bias inherent in the Alpha strategy itself), and the other is the hard constraint carbon screening imposes on the investment universe. The combination of the two may amplify the fund's tracking error relative to its benchmark. Compared with peers, most Paris-Aligned funds tend to emphasize “pursuing returns comparable to the index,” whereas Baillie Gifford clearly implies that its carbon screening will actively sacrifice certain opportunities—this is the key difference from passive Paris-Aligned products.
Table: Comparison of risk types and characteristics
| Risk Type | Nature | Compared with Ordinary Funds |
|---|---|---|
| Emerging market custody risk | Counterparty/custodian credit risk | Larger emerging market exposure, more prominent risk |
| Trading liquidity risk | Market microstructure risk | Redeemability decreases when emerging market trading is restricted |
| Currency risk | Systemic currency risk | Unavoidable under global allocation |
| Price volatility risk | Market risk | More volatile due to the Alpha strategy |
| Carbon screening restriction | Constraint-based strategy risk | Unique to ESG/Paris-Aligned funds |
The document issues separate statements for Israel, Colombia, Chile, Peru, and Mexico. Bringing together the regulatory provisions of these countries outlines the fund's global distribution path:
Table: Regulatory Status Comparison by Country
| Country | Registration Status | Eligible Offerees | Core Legal Basis |
|---|---|---|---|
| Israel | Not specially registered | Sophisticated Investors + Qualified Clients | First Schedule of the Securities Law of 1968; First Schedule of the Investment Advice Law |
| Colombia | Not registered in Colombia's National Securities and Issuers Registry | Private placement only (not publicly tradable) | General Rule No. 336 of 2021 (NCG 336) |
| Chile | Not registered in the CMF Securities Registry or the Foreign Securities Registry | Private placement only; public sales require prior registration | CMF General Rule No. 336 |
| Peru | Not registered in the public registry of the capital market | Institutional investors only | Superintendence of the Capital Market (SMV) |
| Mexico | Not registered in the National Securities Registry | Qualified investors and institutional investors (private placement exemption) | Article 8 of the Securities Market Law |
New Argument One: This layout shows that the fund essentially relies almost entirely on private placement or institutional placement channels to enter emerging markets and specific jurisdictions. Although retail distribution is available in the EU/UK, in Latin America it remains strictly limited to institutional/qualified investors. This also forms a subtle contrast with the description of “all investors” at the beginning of the document — the so-called “all investors” are, in fact, “all investors” in the retail markets of developed countries, while in emerging markets the scope is narrowed to institutional targeting.
New Argument Two: Clause (v) of the Chilean statement specifically states, “This material does not constitute an evaluation or recommendation for investment in financial instruments or investment projects” — reflecting the extreme sensitivity of local regulators’ review of cross-border sales documents. In the statements for each country, Baillie Gifford has consistently adopted a “negative statement” model (“not registered,” “not supervised,” “may not be publicly offered”). This is a form of defensive compliance, designed to place itself within the “private placement exemption” framework of local regulations and avoid triggering the registration obligation for public offerings.
New Argument Three: Mexico’s basis is Article 8 of the Securities Market Law, a typical private placement exemption clause that requires offerees to be “qualified investors.” Peru is even stricter, directly stating, “Individuals and/or entities that do not qualify as institutional investors should not participate in this private placement” — indicating that Peru’s compliance requirements are the most stringent among the fund’s global terms, excluding all individual investors (including high-net-worth individuals).
From the perspective of coverage, these five-country statements are not random selections, but rather full coverage of Latin America’s core capital-market regulators (Chile, Colombia, Peru, Mexico) plus the Middle East hub (Israel). This reflects the radiation logic of Baillie Gifford’s global distribution network: for countries where local capital markets are relatively open but registration thresholds for foreign funds are high, it uses the private placement route to penetrate.
The end of the document lists two separate contact channels:
| Contact Channel | Contact Details | Target Audience |
|---|---|---|
| Client Relations Team / Intermediary Enquiries | 0800 917 2113 (UK toll-free) | Retail investors and intermediaries |
| Institutional Enquiries | +44 (0)131 275 2000 / institutional.enquiries@bailliegifford.com | Institutional investors |
New perspective: The division of phone lines into an “intermediary channel” and an “institutional channel” once again confirms the fund’s distribution strategy: “retail via intermediaries, institutional direct.” This tiered design of the information architecture itself conveys the product positioning—although nominally compatible with mass distribution, it in practice relies more on financial advisors and institutional platforms for reach.
The disclosure details in this follow-up piece offer three observations that go beyond the surface:
1. This fund is a long-term growth vehicle with trade-offs, not a master key to climate solutions. Carbon screening is frankly defined as a constraint rather than an advantage, in sharp contrast to the marketing narratives of other asset managers, which often emphasize ESG "excess returns." Baillie Gifford's narrative is closer to "a willingness to bear opportunity costs for climate goals" — a stance highly consistent with the regulatory spirit of the Paris-Aligned Benchmark (PAB), but one that may weaken its appeal to some investors seeking absolute returns in actual sales.
2. The fund's cross-border sales model of "private placement + institutional targeting" makes its actual investor base far smaller than the scope implied by the phrase "mass market distribution." The retail accessibility of the UK and European markets forms a dual-track structure alongside institutional private placements in Latin America and the Middle East, requiring investors to consider the access conditions of their own jurisdiction when evaluating the fund's liquidity and accessibility.
3. Custody risk, trading risk, and foreign exchange risk are listed side by side in a prominent position, indicating that the fund still maintains a considerable allocation to emerging market assets. This is a result of the global nature of the Global Alpha strategy, and may also reflect the difficulty of finding enough targets in developed markets that both meet carbon screening and satisfy Alpha requirements when pursuing "Paris-Aligned" status, forcing an expansion into emerging markets. Thus, there is a hidden intrinsic linkage between carbon screening and emerging market risk: the stricter the screening, the fewer investable targets, and the more allocation is forced to spread across a broader geographic scope, thereby introducing more emerging market risk. This is a structural trade-off in the fund's strategy design that investors need to understand particularly.
The informational value of this section lies not in revealing new fund details, but in demonstrating how a global fund product seeks a balance among legal compliance, target market positioning, and investment strategy constraints. Behind every legal statement is a precise but conservative sales strategy. For investors, understanding this strategy is more meaningful than understanding the fund's name itself.