Is securities lending excluded?

No. Securities lending of ETFs or index funds, i.e. the lending of these securities, is currently neither applied by True Wealth nor by the custodian bank.

However, if securities lending is correctly secured by means of proper collateral management and the bulk of the resulting proceeds is passed on to the client or pension fund member, there is nothing to be said against securities lending in principle.

It should be noted that securities lending can be used in portfolio management within ETFs and index funds, which is not necessarily a bad thing per se.