Northern Trust Investments, Incorporated

Allegations: THE NORTHERN TRUST COMPANY ("NORTHERN TRUST"), ACTING IN ITS CAPACITY AS A SWAP DEALER, WAS ORDERED TO PAY A $999,000 FINE BY THE NATIONAL FUTURES ASSOCIATION ("NFA"). THE DECISION BY THE NFA'S BUSINESS CONDUCT COMMITTEE ("BCC") WAS BASED ON A COMPLAINT AND A SETTLEMENT OFFER SUBMITTED BY NORTHERN TRUST, IN WHICH IT NEITHER ADMITTED NOR DENIED THE ALLEGATIONS. THE BCC FOUND THAT NORTHERN TRUST COMMITTED THE ALLEGED RULE VIOLATIONS AND CONSIDERED RECENT NORTHERN TRUST REMEDIATION EFFORTS IN ACCEPTING THE SETTLEMENT OFFER. GENERALLY, IT WAS ALLEGED THAT NORTHERN TRUST DID NOT ESTABLISH AND IMPLEMENT ADEQUATE WRITTEN PROCEDURES REASONABLY DESIGNED TO ENSURE THAT NORTHERN TRUST PROVIDED COUNTERPARTIES WITH APPROPRIATE DOCUMENTATION AND DISCLOSURES PRIOR TO OR CONTEMPORANEOUSLY WITH ENTERING INTO SWAP TRANSACTIONS AND DID NOT ESTABLISH A SYSTEM TO DILIGENTLY SUPERVISE ITS SWAP DEALER ACTIVITIES, INCLUDING THE REMEDIATION, RETESTING AND RESOLUTION OF NON-COMPLIANCE ISSUES. Status: Final Sanction Detail: NOT APPLICABLE. Summary: THE NORTHERN TRUST COMPANY ("NORTHERN TRUST"), ACTING IN ITS CAPACITY AS A SWAP DEALER, WAS ORDERED TO PAY A $999,000 FINE BY THE NATIONAL FUTURES ASSOCIATION ("NFA"). THE DECISION BY THE NFA'S BUSINESS CONDUCT COMMITTEE ("BCC") WAS BASED ON A COMPLAINT AND A SETTLEMENT OFFER SUBMITTED BY NORTHERN TRUST, IN WHICH IT NEITHER ADMITTED NOR DENIED THE ALLEGATIONS. THE BCC FOUND THAT NORTHERN TRUST COMMITTED THE ALLEGED RULE VIOLATIONS AND CONSIDERED RECENT NORTHERN TRUST REMEDIATION EFFORTS IN ACCEPTING THE SETTLEMENT OFFER. GENERALLY, IT WAS ALLEGED THAT NORTHERN TRUST DID NOT ESTABLISH AND IMPLEMENT ADEQUATE WRITTEN PROCEDURES REASONABLY DESIGNED TO ENSURE THAT NORTHERN TRUST PROVIDED COUNTERPARTIES WITH APPROPRIATE DOCUMENTATION AND DISCLOSURES PRIOR TO OR CONTEMPORANEOUSLY WITH ENTERING INTO SWAP TRANSACTIONS AND DID NOT ESTABLISH A SYSTEM TO DILIGENTLY SUPERVISE ITS SWAP DEALER ACTIVITIES, INCLUDING THE REMEDIATION, RETESTING AND RESOLUTION OF NON-COMPLIANCE ISSUES.

Allegations: WITHOUT ADMITTING OR DENYING ANY VIOLATION OF THE SHORT SALE RESTRICTION PROVISIONS OF THE KOREAN FINANCIAL INVESTMENT SERVICES AND CAPITAL MARKETS ACT, NORTHERN TRUST INVESTMENTS, INC., AGREED ON NOVEMBER 10, 2022, TO A KOREA FINANCIAL SERVICES COMMISSION ADMINISTRATIVE FINE OF KRW 54,000,000 (APPROXIMATELY USD 41,000) IN CONNECTION WITH THE UNINTENTIONAL SALE OF 18,725 SHARES OF A SECURITY THAT WAS NOT OWNED BY THE NORTHERN TRUST GLOBAL INVESTMENTS-QUANTITATIVE MANAGEMENT COLLECTIVE FUNDS TRUST AT THE TIME THE ORDER WAS PLACED. Status: Final Sanction Detail: THE FINE WAS PAID IN FULL ON NOVEMBER 24, 2022. Summary: WITHOUT ADMITTING OR DENYING ANY VIOLATION OF THE SHORT SALE RESTRICTION PROVISIONS OF THE KOREAN FINANCIAL INVESTMENT SERVICES AND CAPITAL MARKETS ACT, NORTHERN TRUST INVESTMENTS, INC., AGREED ON NOVEMBER 10, 2022, TO A KOREA FINANCIAL SERVICES COMMISSION ADMINISTRATIVE FINE OF KRW 54,000,000 (APPROXIMATELY USD 41,000) IN CONNECTION WITH THE UNINTENTIONAL SALE OF 18,725 SHARES OF A SECURITY THAT WAS NOT OWNED BY THE NORTHERN TRUST GLOBAL INVESTMENTS-QUANTITATIVE MANAGEMENT COLLECTIVE FUNDS TRUST AT THE TIME THE ORDER WAS PLACED.

Allegations: THE AUSTRALIAN SECURITIES & INVESTMENTS COMMISSION ALLEGED THAT CERTAIN DISCLOSURES INCLUDED IN PRODUCT DISCLOSURE STATEMENTS FOR THE NT WORLD GREEN INDEX FUND (THE "FUND") CONTAINED STATEMENTS THAT COULD MISLEAD THE PUBLIC AS TO THE NATURE OR CHARACTERISTICS OF THE FUND. Status: Final Sanction Detail: ON NOVEMBER 23, 2023, THE AUSTRALIAN SECURITIES & INVESTMENTS COMMISSION LEVIED A FINE OF $29,820 AUD (APPROX. $20,270 USD) AGAINST NORTHERN TRUST ASSET MANAGEMENT AUSTRALIA PTY LTD ("NTAMA"). NTAMA, AS INVESTMENT MANAGER FOR THE NT WORLD GREEN TRANSITION INDEX FUND, PAID THE AMOUNT ON DECEMBER 19, 2023. Summary: THE INFRINGEMENT NOTICES FROM THE AUSTRALIAN SECURITIES & INVESTMENTS COMMISSION ("ASIC") WERE RELATED TO THREE SECURITIES WITHIN THE NT WORLD GREEN TRANSITION INDEX FUND'S (THE "FUND") PORTFOLIO (OF OVER 1,250 CONSTITUENTS) AND WITHIN THE INDEX TRACKED BY THE FUND THAT WERE INCONSISTENT WITH ONE ASPECT OF A LOW CARBON INVESTMENT SCREEN. THE MAXIMUM EXPOSURE OF THE THREE SECURITIES IN AGGREGATE WAS LESS THAN $75,000 AUD ($50,000 USD), AND AT NO POINT WAS ANY ONE SECURITY HOLDING GREATER THAN 0.05% OF THE FUND'S NET ASSET VALUE. WITHOUT ADMITTING OR DENYING ANY VIOLATION, NORTHERN TRUST ASSET MANAGEMENT AUSTRALIA PTY LTD, AS INVESTMENT MANAGER FOR THE FUND, PAID $29,820 AUD (APPROX. $20,270 USD) ON DECEMBER 19, 2023 TO COMPLY WITH THE INFRINGEMENT NOTICES FROM ASIC REGARDING ALLEGED FALSE AND MISLEADING STATEMENTS WITHIN THE PRODUCT DISCLOSURE STATEMENTS FOR THE FUND.

Allegations: ON JUNE 18, 2015, THE SECURITIES AND EXCHANGE COMMISSION (SEC) BROUGHT ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS AGAINST 36 MUNICIPAL SECURITIES DEALERS, INCLUDING THE NORTHERN TRUST COMPANY (NORTHERN TRUST), IN WHICH THE SEC ALLEGED THAT THE MUNICIPAL SECURITIES DEALERS CONDUCTED INADEQUATE DUE DILIGENCE EFFORTS IN THE ISSUANCE OF SECURITIES BY CERTAIN MUNICIPAL ISSUERS, AND THEREFORE VIOLATED SECTION 17(A)(2) OF THE SECURITIES ACT OF 1933. NORTHERN TRUST, WITHOUT ADMITTING OR DENYING ANY FINDINGS, CONSENTED TO A $60,000 CIVIL PENALTY IN CONNECTION WITH THREE MUNICIPAL SECURITIES OFFERING THAT TOOK PLACE IN 2010. THE SEC FURTHER ORDERED NORTHERN TRUST AND THE OTHER DEALERS TO RETAIN AN INDEPENDENT CONSULTANT TO REVIEW THEIR POLICIES AND PROCEDURES RELATED TO MUNICIPAL SECURITIES UNDERWRITING DUE DILIGENCE AND TO ADOPT RECOMMENDATIONS MADE BY THE INDEPENDENT CONSULTANT WITHIN NINE MONTHS OF THE ISSUANCE OF THE ORDER. Status: Final Sanction Detail: THE FINE WAS PAID IN FULL ON JUNE 19,2015. Summary: ON JUNE 18, 2015, THE SECURITIES AND EXCHANGE COMMISSION (SEC) BROUGHT ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS AGAINST 36 MUNICIPAL SECURITIES DEALERS, INCLUDING THE NORTHERN TRUST COMPANY (NORTHERN TRUST), IN WHICH THE SEC ALLEGED THAT THE MUNICIPAL SECURITIES DEALERS CONDUCTED INADEQUATE DUE DILIGENCE EFFORTS IN THE ISSUANCE OF SECURITIES BY CERTAIN MUNICIPAL ISSUERS, AND THEREFORE VIOLATED SECTION 17(A)(2) OF THE SECURITIES ACT OF 1933. NORTHERN TRUST, WITHOUT ADMITTING OR DENYING ANY FINDINGS, CONSENTED TO A $60,000 CIVIL PENALTY IN CONNECTION WITH THREE MUNICIPAL SECURITIES OFFERING THAT TOOK PLACE IN 2010. THE SEC FURTHER ORDERED NORTHERN TRUST AND THE OTHER DEALERS TO RETAIN AN INDEPENDENT CONSULTANT TO REVIEW THEIR POLICIES AND PROCEDURES RELATED TO MUNICIPAL SECURITIES UNDERWRITING DUE DILIGENCE AND TO ADOPT RECOMMENDATIONS MADE BY THE INDEPENDENT CONSULTANT WITHIN NINE MONTHS OF THE ISSUANCE OF THE ORDER.

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS OR CONCLUSIONS OF THE COMMODITY FUTURES TRADING COMMISSION ("CFTC"), THE NORTHERN TRUST COMPANY ("TNTC") CONSENTED TO ENTRY OF AN ORDER ISSUED ON SEPTEMBER 30, 2019 FINDING THAT FROM 2013 THROUGH AT LEAST 2018 TNTC FAILED TO REPORT CERTAIN SWAPS TO A SWAP DATA REPOSITORY CONSISTENT WITH THE REQUIREMENTS OF THE COMMODITY EXCHANGE ACT AND CFTC REGULATIONS, AND THAT THOSE SWAP REPORTING FAILURES WERE A DIRECT RESULT OF TNTC'S FAILURE TO ADEQUATELY SUPERVISE ITS SWAP DEALER, INCLUDING FAILING TO HIRE QUALIFIED SUBJECT MATTER EXPERTS TO ENSURE SWAP DEALER COMPLIANCE. THE CFTC'S ORDER REQUIRES THAT TNTC PAY A CIVIL MONETARY PENALTY OF $1 MILLION, AND THAT IT ENHANCE ITS SUPERVISORY PROGRAM, POLICIES, PROCEDURES AND CONTROLS, AND PROVIDE ADDITIONAL TRAINING TO RELEVANT PERSONNEL. TNTC WILL PROVIDE STATUS REPORTS TO THE CFTC CONCERNING ITS REMEDIATION PROGRESS. ADDITIONALLY, TNTC HAS RETAINED OUTSIDE CONSULTANTS TO REVIEW ITS SWAP DEALER PROCESSES AND PROCEDURES, HAS HIRED NEW PERSONNEL TO OVERSEE COMPLIANCE AT ITS SWAP DEALER AND HAS TAKEN SUBSTANTIAL STEPS TO IMPROVE ITS PROCESSES FOR SWAP REPORTING GOING FORWARD. Status: Final Sanction Detail: THE FINE WAS PAID IN FULL ON 10/7/2019. Summary: WITHOUT ADMITTING OR DENYING THE FINDINGS OR CONCLUSIONS OF THE COMMODITY FUTURES TRADING COMMISSION ("CFTC"), THE NORTHERN TRUST COMPANY ("TNTC") CONSENTED TO ENTRY OF AN ORDER ISSUED ON SEPTEMBER 30, 2019 FINDING THAT FROM 2013 THROUGH AT LEAST 2018 TNTC FAILED TO REPORT CERTAIN SWAPS TO A SWAP DATA REPOSITORY CONSISTENT WITH THE REQUIREMENTS OF THE COMMODITY EXCHANGE ACT AND CFTC REGULATIONS, AND THAT THOSE SWAP REPORTING FAILURES WERE A DIRECT RESULT OF TNTC'S FAILURE TO ADEQUATELY SUPERVISE ITS SWAP DEALER, INCLUDING FAILING TO HIRE QUALIFIED SUBJECT MATTER EXPERTS TO ENSURE SWAP DEALER COMPLIANCE. THE CFTC'S ORDER REQUIRES THAT TNTC PAY A CIVIL MONETARY PENALTY OF $1 MILLION, AND THAT IT ENHANCE ITS SUPERVISORY PROGRAM, POLICIES, PROCEDURES AND CONTROLS, AND PROVIDE ADDITIONAL TRAINING TO RELEVANT PERSONNEL. TNTC WILL PROVIDE STATUS REPORTS TO THE CFTC CONCERNING ITS REMEDIATION PROGRESS. ADDITIONALLY, TNTC HAS RETAINED OUTSIDE CONSULTANTS TO REVIEW ITS SWAP DEALER PROCESSES AND PROCEDURES, HAS HIRED NEW PERSONNEL TO OVERSEE COMPLIANCE AT ITS SWAP DEALER AND HAS TAKEN SUBSTANTIAL STEPS TO IMPROVE ITS PROCESSES FOR SWAP REPORTING GOING FORWARD.