Franklin Templeton Investments Corp.

Allegations: ON APRIL 15, 2015, FINANSINSPEKTIONEN, SWEDEN'S FINANCIAL SUPERVISORY AUTHORITY, IMPOSED A PENALTY OF SEK 300,000 (APPROXIMATELY USD 35,659 AT DATE OF PAYMENT) AGAINST FRANKLIN TEMPLETON INVESTMENTS CORP. ("FTIC") IN CONNECTION WITH FTIC'S INADVERTENT FAILURE TO TIMELY REPORT CHANGES IN MAJOR SHAREHOLDINGS OF A CANADIAN ISSUER HELD BY FUNDS AND ACCOUNTS ADVISED BY FTIC. THE CHANGE WAS REPORTED ON A TIMELY BASIS TO CANADIAN SECURITIES REGULATORS, BUT AFTER THE REPORTING DEADLINE IN SWEDEN, WHERE THE CANADIAN ISSUER HAS A DUAL LISTING. FTIC APPEALED THE PENALTY UNSUCCESSFULLY AND THE PENALTY BECAME FINAL ON MARCH 8, 2016. Status: Final Sanction Detail: FINANSINSPEKTIONEN IMPOSED A PENALTY OF SEK 300,000 (APPROXIMATELY USD 35,659 AT DATE OF PAYMENT) Summary: PLEASE SEE RESPONSE TO QUESTION 12.B. ABOVE.

Allegations: ON JULY 2, 2020, THE SEC ENTERED AN ORDER INSTITUTING ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS PURSUANT TO SECTION 9(F) OF THE INVESTMENT COMPANY ACT OF 1940 (THE "INVESTMENT COMPANY ACT") AND SECTIONS 203(E) AND 203(K) OF THE INVESTMENT ADVISERS ACT OF 1940, MAKING FINDINGS, AND IMPOSING REMEDIAL SANCTIONS AND A CEASE-AND-DESIST ORDER AGAINST REGISTRANT (THE "ORDER"). IN THE ORDER, THE SEC FOUND THAT AT VARIOUS POINTS BETWEEN OCTOBER 2013 AND SEPTEMBER 2016, REGISTRANT CAUSED CERTAIN FRANKLIN TEMPLETON FUNDS IT MANAGES TO INVEST IN SHARES OF TWO UNAFFILIATED EXCHANGED-TRADED FUNDS IN EXCESS OF THE 3% INVESTMENT LIMIT UNDER SECTION 12(D)(1)(A)(I) OF THE INVESTMENT COMPANY ACT. REGISTRANT NEITHER ADMITTED NOR DENIED THE SEC'S FINDINGS. Status: Final Sanction Detail: MONETARY/FINE (AMOUNT $75,000); CEASE AND DESIST Summary: WITHOUT ADMITTING OR DENYING THE FINDINGS IN THE ORDER, REGISTRANT CONSENTED TO ITS ENTRY. ON JULY 2, 2020, THE SEC ENTERED THE ORDER.

Allegations: ON AUGUST 27, 2018, THE SEC ISSUED AN ORDER THAT FOUND THAT LEGG MASON HAD VIOLATED SECTION 13(B)(2)(B) OF THE SECURITIES EXCHANGE ACT OF 1934 BY FAILING TO DEVISE AND MAINTAIN A SYSTEM OF APPROPRIATE INTERNAL ACCOUNTING CONTROLS WITH RESPECT TO THE USE OF INTRODUCING BROKERS AND OTHER INTERMEDIARIES IN EMERGING MARKETS, INCLUDING LIBYA, AND THAT IMPOSED A CEASE-AND-DESIST ORDER ON LEGG MASON WITH RESPECT TO ANY VIOLATIONS OR FUTURE VIOLATIONS OF SECTION 13(B)(2)(B). PREVIOUSLY, LEGG MASON HAD SUBMITTED AN OFFER OF SETTLEMENT IN CONNECTION WITH THE MATTER WHICH THE SEC DETERMINED TO ACCEPT. THE ORDER RESOLVED A FCPA INVESTIGATION CONCERNING THE ACTIVITIES OF LEGG MASON'S FORMER PERMAL BUSINESS IN CONNECTION WITH MANAGING ASSETS OF LIBYAN GOVERNMENTAL ENTITIES IN STRUCTURES ESTABLISHED BY A THIRD-PARTY FINANCIAL INSTITUTION. THOSE INVESTMENTS WERE MADE IN CALENDAR YEARS 2005-2007 AND ALL WERE TERMINATED BY 2012. THE MATTER DOES NOT RELATE TO ANY CURRENT BUSINESS ACTIVITIES OR CLIENT RELATIONSHIPS OF LEGG MASON OR ANY AFFILIATE, AND WAS FOCUSED ON THE ACTIONS OF FORMER PERMAL EMPLOYEES WHO LEFT THAT FIRM IN 2013. LEGG MASON BECAME AN ADVISORY AFFILIATE OF REGISTRANT IN JUNE 2021. Status: Final Sanction Detail: THE ORDER REQUIRED LEGG MASON TO PAY DISGORGEMENT OF $27,594,729 AND PREJUDGMENT INTEREST OF $6,907,765 TO THE SEC. THE SEC DID NOT IMPOSE ITS OWN PENALTY BASED UPON THE PENALTY PAID TO RESOLVE A DOJ INVESTIGATION ARISING OUT OF THE SAME MATTER, AS DESCRIBED IN THE RESPONSE TO ITEM 2 ABOVE. Summary: ON AUGUST 27, 2018, THE SEC ISSUED AN ORDER THAT CONTAINED FINDINGS THAT LEGG MASON HAD VIOLATED SECTION 13(B)(2)(B) OF THE SECURITIES EXCHANGE ACT BY FAILING TO DEVISE AND MAINTAIN APPROPRIATE INTERNAL ACCOUNTING CONTROLS WITH RESPECT TO THE USE OF INTRODUCING BROKERS AND OTHER INTERMEDIARIES IN EMERGING MARKETS, INCLUDING LIBYA, AND THAT IMPOSED A CEASE-AND-DESIST ORDER ON LEGG MASON WITH RESPECT TO ANY VIOLATIONS OR FUTURE VIOLATIONS OF SECTION 13(B)(2)(B). PREVIOUSLY, LEGG MASON HAD SUBMITTED AN OFFER OF SETTLEMENT WHICH THE SEC DETERMINED TO ACCEPT. THE ORDER RESOLVED A FCPA INVESTIGATION CONCERNING THE ACTIVITIES OF LEGG MASON'S FORMER PERMAL BUSINESS IN CONNECTION WITH MANAGING ASSETS OF LIBYAN GOVERNMENTAL ENTITIES IN STRUCTURES ESTABLISHED BY A THIRD-PARTY FINANCIAL INSTITUTION. PURSUANT TO THE ORDER, THE SEC ORDERED LEGG MASON TO CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND FUTURE VIOLATIONS OF SECTION 13(B)(2)(B) OF THE SECURITIES EXCHANGE ACT OF 1934 AND TO PAY DISGORGEMENT OF $27,594,729 AND PREJUDGMENT INTEREST OF $6,907,765 FOR A TOTAL PAYMENT OF $34,502,944. SEPARATELY, ON JUNE 4, 2018 LEGG MASON AGREED TO PAY A PENALTY AND DISGORGEMENT TO RESOLVE A DOJ INVESTIGATION ARISING OUT OF THE SAME MATTER, AS DESCRIBED IN THE RESPONSE TO ITEM 2 ABOVE.