Baillie Gifford Pacific Fund Factsheet

This Month's Scorecard

As of 30 June 2026, the fund returned +44.8% over the past six months and +81.3% over the past year, outperforming the MSCI AC Asia ex Japan benchmark by +16.8 and +30.1 percentage points, respectively; the five-year annualized return was +9.7% vs. +8.6% for the benchmark.

The fund's objective is to outperform the MSCI AC Asia ex Japan on a rolling five-year basis, in sterling terms, after fees; the manager also believes the IA Asia Pacific (ex Japan) sector is an appropriate comparator. On a rolling five-year basis, the annualized excess return narrows to about 1.1 percentage points—the strong outperformance over the past year has significantly boosted the long-term figures, but the report itself provides no attribution data.

Metric	6 months	1 year	3 years (annualized)	5 years (annualized)
Fund (Class B-Acc)	44.8	81.3	28.7	9.7
Benchmark (MSCI AC Asia ex Japan)	28.0	51.2	23.1	8.6
Industry average (IA Asia Pacific ex Japan)	26.6	46.9	19.0	7.8

Annual returns have been highly volatile: of the five rolling years, two were negative—21/22 fiscal year -20.0%, 22/23 fiscal year -7.0%; the 24/25 fiscal year returned -1.6%, underperforming the benchmark by 10 percentage points; the 25/26 fiscal year returned +81.3%, outperforming the index (+51.2%) and the industry average (+46.9%) by about 30 percentage points.

Year (ended 6/30)	21/22	22/23	23/24	24/25	25/26
Fund	-20.0	-7.0	19.7	-1.6	81.3
Benchmark	-14.4	-5.2	13.9	8.4	51.2
Industry average	-10.8	-3.3	10.0	4.4	46.9

How the Manager Views the Market

Manager stance [neutral/no directional view]—the first part contains no macro or market judgment, only an investment philosophy centered on long-term growth stocks.

• The fund is positioned as a long-term Asian (ex-Japan) growth fund, aiming to find quality companies that can outperform over five years or more; it has a "strong preference for growth" (in the report's own words: strong preference for growth).
• It is "relatively index and sector agnostic" (in the report's own words: relatively index and sector agnostic)—it first looks for the best long-term names, then determines which country and sector they belong to.
• The portfolio typically holds 50–100 stocks with low turnover, drawing on Baillie Gifford's global investment research resources; this period actually held 70 names with annual turnover of 46%, consistent with that self-description.
• The report nowhere discusses valuation, interest rates, or macro risks—this is stock-selection material, not a market-timing view. All of the above positioning statements are the fund's own descriptions (from the holder's perspective), with a product-description tone; a third party cannot verify the "quality company" judgment itself from this text.

How Positions Moved: Where They Were Raised, Where They Were Trimmed

The report discloses no buy/sell activity for the period—there is no data on new positions, additions, reductions, or full exits. All of the following are period-end static positions; the trading direction of each holding is not indicated.

The top ten holdings account for 55.6% of assets, of which seven are technology/semiconductor-related, totaling 47.2%:

Holding	% of assets
TSMC	9.0
Samsung Electronics	8.9
SK Hynix	8.0
SK Square	7.8
MediaTek	5.1
Montage Technology	4.4
Nanya Technology Company	4.0
Tencent	3.9
CNOOC	2.3
Accton Technology	2.2

Sector allocation is as follows (the original table totals 98.4%, with cash separately listed at 1.6%; this table reproduces the row data as originally presented):

Sector	Fund %	Benchmark %	Difference (pp)
Information Technology	53.5	50.4	+3.1
Industrials	15.5	7.6	+7.9
Financials	8.4	16.2	-7.8
Consumer Discretionary	8.2	7.7	+0.5
Materials	6.2	3.0	+3.2
Communication Services	3.9	5.9	-2.0
Energy	2.3	2.0	+0.4
Real Estate	0.4	1.3	-0.9
Health Care	0.0	2.5	-2.5
Cash	1.6	0.0	+1.6

Regional allocation (top ten regions):

Region	Fund %	Benchmark %	Difference (pp)
China	30.8	21.2	+9.5
South Korea	29.2	26.4	+2.8
Taiwan	23.3	30.5	-7.1
India	5.3	12.4	-7.0
Vietnam	3.2	0.0	+3.2
Hong Kong	2.1	3.3	-1.3
Singapore	1.5	3.3	-1.7
Kazakhstan	1.1	0.0	+1.1
Thailand	0.9	1.1	-0.2
Indonesia	0.9	0.5	+0.4

Structural observations: China, South Korea, and Taiwan together account for 83.3%, leaving the portfolio highly concentrated in the Northeast Asian technology chain; period-end cash was 1.6% (including unsettled cash flows), active share was 62%, and the portfolio was effectively fully invested; no leverage, long/short ratio, or derivative positions are disclosed. The main deviations from the benchmark: by sector, overweight industrials (+7.9pp) and underweight financials (-7.8pp); by region, overweight China (+9.5pp), holdings in Vietnam and Kazakhstan with zero benchmark weight, and underweights in Taiwan (-7.1pp) and India (-7.0pp). This is consistent with the "index/sector agnostic" stock-selection logic above, but it does not represent the month's fund flows.

Fund Facts

Fund size £4,617.97m, currently holding 70 positions; co-managed by Roderick Snell (Partner) and Ben Durrant; launched on 17 March 1989; OEIC structure.

• Share classes: Class B-Acc / Class B-Inc; annual management fee 0.65%, OCF 0.71%, historical dividend yield 0.30%.
• IA peer-group ranking: 15/114 over 6 months, 11/114 over 1 year, 7/110 over 3 years, 31/106 over 5 years.
• One more specific item in the risk warnings: assets held in custody in emerging markets are exposed to the risk of loss from custodian insolvency or negligence; the fund does not provide capital protection and is not suitable for investors seeking short-term returns, regular income, or an investment period of less than five years.

Continuation Analysis (Part 2/2)

I. A Structural Interpretation of the Multi-Jurisdiction Compliance Statements

The latter half of this page presents the regulatory compliance statements for five jurisdictions (Israel, Chile, Colombia, Peru, Mexico). These statements appear to be standardized legal texts, but in fact reflect the fund manager's (Baillie Gifford's) differentiated response strategies to different regulatory frameworks, and are worth unpacking layer by layer.

1. Differences in Disclosure Depth Among Country Statements

Jurisdiction	Statement Length	Regulatory Level Cited	Core Regulatory Stance	Degree of Restriction on Investors
Israel	Medium	First Schedule of the two laws	Passive exclusion through investor classification	Requires satisfying both categories of investor conditions
Chile	Longest	Specific to Norma de Carácter General N° 336	Proactive statement of exemption + unregistered risk	No public offering + not subject to regulatory review
Colombia	Medium	Refers to National Registry + stock exchange	Reverse confirmation: if unregistered, no public offering	Requires investors to bear their own compliance obligations
Peru	Most concise	Refers to SMV and Public Registry	Passive statement: no review submitted	Institutional investors only
Mexico	Medium	Explicitly cites Article 8 of the Securities Market Law	Proactively invokes a private-placement exemption path	Limited to qualified/institutional investors

Key observations:

• Chile's statement has the highest information density, covering five layers—the basis for exemption, the fact of non-registration, the absence of a public-information obligation, offering restrictions, and disclaimer clauses—forming a complete legal argument.
• Mexico is the only jurisdiction that explicitly cites a specific legal provision (Article 8), indicating that it adopts a "positive exemption" strategy rather than the "negative exclusion" strategy used by other jurisdictions.
• Peru's statement is the most concise, emphasizing only three points—"unregistered + unreviewed + institutional-investor limitation"—which may reflect that the jurisdiction's regulatory framework has already established a relatively standardized precedent for private placements by offshore funds, requiring little elaboration.

2. Hidden Legal Risk Mapping

From the wording details of these statements, one can infer in reverse the fund manager's priority ranking of legal risks across countries:

• Israel: requiring the two categories "Sophisticated Investors" and "Qualified Clients" to be met in parallel ("at least one category in each"), meaning investors must simultaneously satisfy the corresponding categories under both laws—this is stricter than compliance with a single law and significantly narrows the sellable universe.
• Colombia's wording is the most defensive: it requires investors (rather than the fund) to acknowledge that they are the "sole liable party for full compliance". This is a classic liability-transfer mechanism, contractually shifting compliance risk to end investors in advance.
• Chile's statement repeats "unregistered" twice (Registro de Valores / Registro de Valores Extranjeros) and stresses that it is "not subject to its supervision"—this is the strongest risk warning to potential investors, implying that if the fund encounters redemption problems, Chilean regulators will not provide any investor protection.

II. The "China Market" Special Note in the Risk Warnings

The risk statement singles out China, listing market volatility, market shutdown, trading, liquidity, settlement, corporate governance, regulation, and taxation side by side. This is consistent with the fund's investment scope (the Pacific Fund covers Asian markets), but two points are worth noting:

1. "Market shutdown risk" is explicitly mentioned—this is not groundless in the context of Chinese securities regulation. The A-share circuit breaker mechanism introduced in 2015 was suspended after just four days of implementation; the temporary market closure during the Wuhan pandemic in 2020; and the quantitative-trading restrictions in early 2024 all demonstrate the unpredictability of trading that regulatory intervention can cause.

2. Investment in frontier markets further amplifies the above risks—frontier markets (such as Vietnam, Pakistan, Bangladesh, etc.) have weaker capital-market infrastructure, and when combined with the systemic risks of the Chinese market, they make the fund's dual emerging-market risk exposure a core risk factor.

III. Timeliness and Functional Boundaries of Rating Information

The final page presents the Morningstar Medalist Rating™ as of 31 May 2026, along with ratings from Rayner Spencer Mills Research and FundCalibre, but there are notable time-lag issues:

Rating Source	Data Cutoff Date	Fund Report Date	Time Lag
Morningstar Medalist Rating™	31 May 2026	30 June 2026	1 month
FundCalibre / Rayner Spencer Mills	Not stated	30 June 2026	Unknown

Analysis points:

• The Morningstar Medalist Rating™ is an analyst-driven assessment, with 100% data coverage (the "Data Coverage %" column in the table is blank, but the rating itself is fully presented). The rating was published one month before the end of the report period, meaning it reflects the fund's risk-return profile as of the end of May, not its state at the end of June—given the high volatility of emerging markets (especially China), fundamental changes within one month may already have made the rating relatively stale.
• The three rating agencies are presented side by side, but the nature of the ratings differs: Morningstar is the most independent third-party rating provider; FundCalibre and Rayner Spencer Mills, while still independent institutions, have business models more oriented toward selling rating tools to financial advisers, and their ratings differ from Morningstar's in terms of use cases.
• The page explicitly states "These ratings are not a recommendation to buy"—a standard disclaimer under UK FCA rules, acknowledging that the ratings are for reference only and do not constitute investment advice, thereby drawing a clear boundary of responsibility at the consumer-protection level.

IV. The Strategic Intent of the Compliance Text: Managing Cost Through Format

Overall, the multi-jurisdiction statements in this factsheet are essentially the embodiment of a low-cost compliance strategy:

• Through a standardized template (the same paragraph structure applies to all countries), Baillie Gifford avoids the cost of drafting customized legal documents for each jurisdiction;
• Yet within the template, it retains carefully differentiated wording (such as Chile's five-point structure and Mexico's citation of Article 8), reflecting the fund's legal team's precise grasp of each country's regulatory details;
• The very existence of these statements itself indicates that the fund has conducted, or plans to conduct, private placements or sales in the listed countries, and therefore pre-declares its compliance status to reduce the possibility of future regulatory disputes.

This "template + differentiated fill-in" approach is a typical practice in the cross-border fund industry, but its effectiveness depends on host-country regulators' acceptance of template-style statements—for Israel and Mexico, the explicit citation of legal provisions provides a verifiable compliance basis; for Peru and Colombia, whether the formalized framework of the non-registration declarations can withstand future regulatory changes remains uncertain.

V. Summary

The substantive information density of this continuation is far higher than its surface form suggests. The multi-country compliance statements not only reveal the cross-border distribution footprint of the fund, but also map the differentiated constraints that different regulatory ecosystems impose on the same offshore fund. The special mention of the Chinese market in the risk warnings, the layered risks of frontier markets, and the time lag in the rating information together constitute an information gap that investors must actively fill during due diligence—the compliance completeness of the document itself does not equal the informational completeness required for an investment decision.