Xtrackers UD Green Infrastructure Select Equity ETF

Investment Objective

The Fund seeks investment results that correspond generally to the performance, before fees and expenses, of the Solactive United States Green Infrastructure ESG Screened Index (the “Underlying Index”).

Sustainable Category

Primary: Thematic Investing (green mobility, green fuel, green energy, green wholesale power, environmental services, and pollution control business classification).

Secondary: Negative/Exclusionary Screening (UN Global Compact violators; Sustainalytics ESG Risk Score ≥40 excluded; controversial weapons, tobacco, thermal coal, oil sands, and small arms/military exclusions).

Underlying Index

Solactive United States Green Infrastructure ESG Screened Index

Index Provider

Solactive AG, using ESG data supplied by Sustainalytics

Parent (Base) Index / Universe

Solactive GBS United States All Cap Index

Construction Approach

From the US all-cap universe: companies must be headquartered in the US, meet minimum free-float market cap (≥$100mm) and liquidity (≥$1mm average daily value traded) thresholds, and be classified under specific green-infrastructure RBICS industry codes (green mobility, green fuel, green energy, green wholesale power, environmental services, pollution control). Remaining companies are then screened against ESG/business-involvement criteria (below). The top 50 companies by free-float market cap are selected, with a maximum of 10 per category; rebalanced quarterly.

ESG Rating / Scoring Threshold

Companies with a Sustainalytics ESG Risk Score of 40 or higher (“Severe” risk) are excluded — a maximum-risk-score cutoff rather than a minimum-quality bar.

Exclusions / Screens

●       UN Global Compact violators

●       Controversial weapons (any detectable involvement)

●       Tobacco (production; or ≥5% revenue from related products/services/retail; or ≥10% ownership of a producer)

●       Thermal coal (≥5% revenue from extraction or power generation; or ≥10% ownership)

●       Oil sands (≥5% revenue from extraction; or ≥10% ownership)

●       Small arms / military contracting (multiple revenue-based thresholds, generally 5%–10%)

Weighting Methodology

Equal-weighted among the top 50 selected securities, with a maximum of 10 securities per green-infrastructure category — distinct from the market-cap-based approaches used by GRID and EFRA.

Risk / Tracking-Error Constraints

No explicit tracking-error budget is disclosed. Equal weighting across a concentrated universe (up to 50 names) means the Fund’s risk/return profile is expected to diverge materially from broad-market benchmarks.

Shareholder-Issuer Engagement / Proxy Voting

NA (no pass-through voting for this Fund).

DWS votes proxies on the Fund’s behalf per DWS’s Proxy Voting Policy and Guidelines, administered with Institutional Shareholder Services (ISS) as proxy vendor.

Reporting / Disclosure

No fund-specific “Sustainability Characteristics”-style report identified for UPGR comparable to BlackRock’s; DWS provides standard fund fact sheets and prospectus/SAI disclosure via etf.dws.com.

Notes

-ESG screening is based on a continuous risk score (Sustainalytics ESG Risk Score ≥40 excluded) rather than category exclusions alone, and the only one using equal weighting rather than a market-cap-based scheme. Very small AUM ($0.6mm) — among the smallest funds in the broader fund list.

-Sustainable categories fall into seven buckets: 1. Values-based investing, 2. Negative/positive screening or exclusionary strategies, 3. Impact investing, 4. Thematic investing, 5. ESG integration, 6. Shareholder advocacy, issuer engagement and proxy voting, and 7. Structural sustainability.  These are not mutually exclusive.  The primary and secondary sustainable investing approaches will be identified under the Sustainable Category.